DCIT Vs M/s Delhi Tourism Transportation Corporation Ltd. (ITAT Delhi) The addition was made by the AO on the ground that although the assessee had claimed credit for Tax Deducted at Source (“TDS”, for short) on the interest income from the bank, corresponding interest income was not offered to tax by the assessee during the […]
Since assessee had explained that the two partners had cash deposited out of the cash receipts against advanced sale of land in individual however, assessee could not furnish any details evidence of holding of land, agreement with the purchasers and date/mode of source of receipts either before AO or before CIT(A), therefore, AO was correct in holding these credits as unexplained in the hands of assessee.
Explore the ITAT Mumbai judgment in Anandkumar Jain vs ITO, highlighting rectification under Section 154 for deduction under Section 80HHC based on subsequent Supreme Court decisions.
Satish Kumar Vs ITO (ITAT Delhi) It is an admitted fact that assessee filed reply in response to the notice under section 148 of the I.T. Act and submitted before A.O. that original return filed before him may be treated as return filed in response to the notice under section 148 of the I.T. Act. […]
Assessee had only purchased software internally developed by non-resident and non-resident had not passed the copyright and only ‘right to use’ had been given to assessee and as such ‘right to use’ was akin to purchase of copyrighted article and in the absence of purchase of any copyright in the article, the assessee could not be held liable to deduct tax at source out of such payments.
DCIT Vs M/s. DLF Assets Pvt. Ltd. (ITAT Delhi) On the aspect of disallowance made by the Ld. AO by invoking the provisions u/s 14A of the Act r/w Rule 8D (2) (ii) of the Rules, it is the submission of the Ld. AR that the interest expenses net of interest income may be considered […]
The assessee had challenged reopening of assessment on two grounds. The CIT(A) had accepted the arguments of the assessee, in light of provisions of section 147 of the Act, and the assessment order passed by the AO u/s 143(3) of the Act, dated 29/12/2018 and came to the conclusion that the assessment has been reopened on change of opinion without there being any tangible material, in the possession of the AO, which suggest escapement of income.
M/s Ram Lal Bhasin Public School Vs CIT (ITAT Amritsar) For claiming exemption u/s 10(23C)(iiiad) of the Act, the entity must be an University or other educational institute existing solely for educational purpose and not of the purposes of profit. In the present case it is not in dispute that the assessee is a school […]
ITO Vs Shri Kantilal G. Kotecha (ITAT Mumbai) We find that with regard to claim of deduction u/s 54 of the Act, this tribunal in quantum proceedings had granted deduction u/s 54 of the Act to the extent of payments made within the prescribed limitation period i.e payments made within one year prior to the […]
ACIT Vs Shri Anil Gulabdas Shah (ITAT Mumbai) The undisputed position that emerges is the fact that the property under consideration was subject matter of extensive litigation which ultimate got culminated into sale of the property by the assessee in terms of consent terms dated 03/01/2012 between the assessee and certain other parties. The assessee, […]
