Shri Sanjay Kaul Vs ITO (ITAT Delhi) Whether the transaction carried out by the assessee and the claim of the short Term Capital Loss is in the normal course of the investment activity of the assessee. We find that the Assessing Officer has referred to investigation done by the Directorate of Investigation, Kolkata, to highlight the […]
The issue under consideration is whether the stamp duty valuation at the time of first digital payment can be adopted if the agreement to sale is lost or inaccessible for any reason whatsoever?
The issue under consideration is whether addition made on account of Advertisement, Marketing, and Sales Promotion (AMP) transactions is justified in law?
DCIT Vs Bhoruka Power Corporation Ltd. (ITAT Bangalore) The issue under consideration is whether receipt on account of sale of carbon credit is Revenue Receipt or Capital Receipt? ITAT states that carbon credit is in the nature of ‘an entitlement’ received to improve world atmosphere and environment reducing carbon, heat and gas emissions. The entitlement […]
Delhi Police Education Fund Vs CIT (ITAT Delhi) Assessee argued that the assessee is involved in promoting the post Higher Secondary Education and fulfils the test of Section 2(15) of the Act, the definition of charitable purpose. Ld. DR argued that the assessee’s activities are limited to the wards of the Police personnel. Hence, it […]
Edenred Pte Ltd. Vs DDIT (ITAT Mumbai) In the instant case, the appellant has received fees for referral services/other services of Rs.39,94,209/- from Surf Gold in the year under consideration. It is relevant to mention here that as per the India-Singapore DTAA, the services in the nature of managerial, technical or consultancy nature are taxable […]
The issue under consideration is whether provisions of section 56(2)(vii)(b)(ii) are applicable on difference between consideration paid for purchase of property and SRO value as on date of agreement?
ITO Vs Shri Sunil Govind Agre (ITAT Mumbai) During the course of assessment proceedings, the AO called for information u/s 133(6) from the above two parties in order to verify the genuineness of transactions. However, the notices sent by him could not be served and these were returned un-served by the postal authorities with the […]
IBM India Pvt. Ltd. Vs ACIT (ITAT Bangalore) It has been submitted by Ld.Counsel that as a consequence of APA entered into by assessee, income was increased vis-a-vis original computation at page 322. Referring to revised computation at page 328 of paper book volume 1, he submitted that, incremental increase in the income is Rs.7,74,2 […]
Bureau Veritas Consumer Products Services (India) Private Limited Vs ACIT (ITAT Delhi) ITAT held that It is true that the assessee has paid rebate/discount to its overseas AEs. It is equally true that such arrangement has been done through Master Service Agreements (‘MSA’) with various overseas companies (sample JC Penny ) for providing testing and […]