M/s. Blue Yonder India Private Limited, (Formerly JDA Software India Private Limited) Vs DCIT (ITAT Bangalore) E-INFOCHIPS LIMITED- The Annual Report of e-Zest Solutions Limited for assessment year 2010-2011 (placed at page 527 to 534 of the paper book) clearly demonstrates that it is engaged in end to end product development, including product design and […]
Reopening of assessment under section 147 was not justified when there was no evidence to show that there was escapement of income due to failure on the part of assessee to disclose fully and truly all material facts necessary for assessment.
It is open to the parties in Transfer Pricing cases to take a stand contrary to their TP study, if they contend that the stand taken in the TP study is contrary to facts or was erroneous. Such a claim cannot be disregarded only on the basis that it is contrary to Assessee’s own stand in the TP study.
Nike India Pvt Ltd vs DCIT (ITAT Bangalore) The AO noticed that the assessee has claimed deduction for ‘Provision for sales returns’. When enquired, the assessee submitted that it creates a provision for anticipated sales returns based on a percentage of the sales made each month. It was further submitted that the provision is created […]
GSE Commerce Private Ltd. Vs ACIT (ITAT Bangalore) The A.O. was of the view that the shares of the company have been over valued and accordingly asked the assessee to justify the valuation. After considering the explanations of the assessee, the A.O. took the view that the valuation report has been prepared on the basis […]
Since assessee had expended the amount well within period of 3 years from the date of sale of original asset, assessee was entitled to proportionate deduction under section 54F though the assessee had not deposited capital gains amount in the Capital Gains Account Scheme within the prescribed time.
Joseph Davaraj Koilpillai Vs ITO (ITAT Bangalore) Deduction on account of bad debt as allowed u/s 36(1)(vii) read with section 36(2), after amendment by the Direct Tax Laws (Amendment) Act 1987, envisage merely wiring off the debt as irrecoverable in the accounts of the assessee as a condition for such an allowance. Before the amendment […]
The issue under consideration is whether CIT(A) is correct in confirming the enhancement of disallowance made by the AO over and above the amount disallowed by the assessee u/s 14A of the Act?
The issue under consideration is whether the sum of admission fees paid to stock exchange will be allowed as capital expenditure? In light of Hon’ble Supreme Court judgement in the case of Techno Shares and Stocks Limited (supra) membership of stock exchange is to be treated as a capital asset.
DCIT Vs Ocwen Financial Solutions Pvt. Ltd.(ITAT Bangalore) Facts- 1. Treatment of expenditure incurred on buy-back of shares- An assessee has spent amount of INR 8,90,961 on buy-back of shares and debited the same to Profit & Loss Account treating the same as ‘revenue expenditure’. AO treated the same as ‘capital expenditure’. 2. Set-off of […]
