Dart Infrabuild (P) Ltd. Vs ITO (ITAT Delhi) A conjointly reading of section 148 (1) of the Act with section 139 (4) of the Act and section 144 of the Act makes it abundantly clear that pursuant to the notice under section 148 of the Act, if an assessee files a belated return or letter […]
ITAT Mumbai: Anil K. Shah’s appeal against reassessment. Challenges various additions including expenses, borrowed funds, and alleged bogus purchases. Legal and evidential arguments presented.
Toyoda Micromatic Machinery India Private Ltd. Vs DCIT (ITAT Delhi) It is a fact that the learned assessing officer has not challenged the order of the learned CIT – A stating that resale price method is the most appropriate method as assessee does not engage in any deemed manufacturing or further value addition. It is […]
Google India Private Limited Vs JCIT (ITAT Bangalore) By this Stay Petition, the assessee is seeking to stay the recovery of outstanding tax arrears of Rs.1260,56,49,209. 2. Originally the stay was granted vide the order dated 20.11.2019 of the Tribunal in SP No. 293/Bang/2019, for a period of six months. As per the original stay […]
Where assessee-trust was collecting fees from different organizations towards training programmes and it also received rent for letting out its part premises; the CIT was justified in rejecting the assessee s application for grant of registration under section 12AA on the ground that the activities of the trust were not charitable, but were commercial in nature.
Minimum guarantee amount which was paid by the distributor for acquiring the exhibition rights of a movie was a fixed expenditure for the distributor that was paid to producers irrespective of the fact whether the film generated a profit or incurs losses. Hence, the payments made by assessee did not fall under the term Royalty and did not attract the provisions of TDS.
Provision for software expenses could not be disallowed by considering it as contingent liability as assessee was required to make provision for all known liabilities and losses as per accounting standards prescribed by ICAI and also by the Central Government under the Income Tax Act even though the amount could not be determined with certainty.
Wipro GE Healthcare Pvt. Ltd. Vs DCIT (ITAT Bangalore) In respect of transfer pricing addition made by Ld.AO. It is observed that DRP/TPO for year under consideration did not consider objections raised by assessee against comparables selected by Ld.TPO and simply followed DRP directions issued for AY 2014-15. As AY: 2014-15 has been set aside […]
DCIT Vs Gayatri Construction (ITAT Ahmedabad) Ld. counsel has submitted that advances were given to Ramjibhai and Company for business purpose and petrol and diesel was also purchased from them. The ld. Counsel has also contended that assessee was having interest free fund of Rs. 64,75,145/-. The ld. counsel has also placed reliance on the […]
PCIT cannot form another view on the same issue in which the Assessing Officer has already satisfied himself and passed an order which clearly indicates that the Assessing Officer has verified and investigated the matter in detail.
