Since, no specific format is provided under the Act for recording satisfaction for making dis allowance under section 14A, AO was not required to give detailed reasons for invocation of rule 8D(2) in view of the fact that assessee failed to discharge its primary onus of proving nexus between interest-free funds and the investments yielding tax- free income.
When the business asset of the assessee is let out but after discontinuing the business activity of the textile mill then the rental income cannot be treated as income from house property however the same would be assessed as income from other sources.
The credit of TDS deducted and deposited in the old name and old PAN No. and the credit of the same was not given to the assessee on account of mismatch, though entity is the same.
These are appeals filed by the assessee-company directed against the assessment orders dated 24.12.2014, 17.12.2015 and 30.11.2016 for the assessment years 2010-11, 2011-12 and 2012-13 respectively u/s. 143(3) r.w.s. 144C of the Act by the Deputy Commissioner of Income-tax / Assistant Commissioner of Income-tax, Circle-4(1)(1), Bangalore.
Any secret transaction/payment that is made to secure an unfair advantage, would necessarily be repugnant to law. Transaction which is not transparent, offends normal business practice, must suffer scrutiny.
Provisions of section 10(5) of were introduced in order to motivate the employees and also to encourage tourism in India and, therefore, the reimbursement of LTC/LFC was exempted, but, there was no intention of the Legislature to allow the employees to travel abroad under the garb of benefit of LTC available by virtue of s.10(5) […]
It cannot be denied that expenditure incurred by the assessee for the purpose of developing housing project and not allowable by virtue of section 40(a)(ia) would ultimately go to increase assessee’s profit from such business and profit as computed after making the dis allowance would, therefore, qualify for deduction under section 10A.
These appeals are preferred by the assessee against the order of CIT(A) on common grounds. Therefore, these appeals were heard together and are being disposed off through this consolidated order.
Insurance & Travelling Expenses incurred in Foreign Currency needs to be Excluded from both Export and Total Turnover for the purpose of section 10A Calculations
Bombay High Court decision upheld the DRP order in excluding 6 companies, from the list of comparables chosen by the TPO, on the basis of turnover and size. Following it , we uphold the DRP order in excluding the above 6 companies, from the list of comparables chosen by the TPO, on the basis of turnover and size.
