The petitioner was a firm of auditors. During the course of search and seizure operations conducted against EMAAR, the laptop computers of two employees of the petitioner, who were conducting an audit of EMAAR, were seized by the Deputy Director.
In the absence of any specific provision under which the so called notional income on advances, could be brought to tax, we do not see as to how the impugned orders passed by the Commissioner of Income Tax can be sustained.
There is nothing in Section 80I(2)(iv) to say that the relationship in order to qualify for the term employment must be one of master and servant and cannot extend to contractual employment. That the concept of permanent or direct workmen is the precondition envisioned in Section 80I(2) when it was the term employs does not appear to be reflected in the statute.
Only amount which an assessee aggrieved by delayed payment can legitimately claim under the statute is interest and that no other interest on such statutory interest is payable. CIT Vs. Indian Farmer Fertilizer Co-operative (Delhi High Court)
Assessment proceedings under the Income Tax Act are not a game of hide and seek. The inquiry in the wake of a notice under Section 148 is not an empty formality. It must be effective and with a sense of purpose.
The petitioner has filed an appeal being ITA No.825/Del/2014 before the Income Tax Appellate Tribunal being aggrieved by the order passed by the Dispute Resolution Panel on 31.10.2013. The Tribunal, at the initial stage, that is, on 31.03.2014, had granted stay of the demand which had been raised subsequent to the said order
For the assessment year 2008-09 the assessee had reported a tax exempt income to the tune of Rs. 18,26,360/- amongst other heads of income. The AO added back Rs. 19,96,242/- under Section 14A. While doing so, the AO applied Rule 8D by taking into consideration the total quantum of interest other than that invested
The ITAT considered the submissions and concluded that the AO could not have brought to tax the amounts that he ultimately did merely based upon the DVO’s report in the absence of any material pointing to under valuation.
The writ petitioner under Article 226/227 of the Constitution ofIndia, is a company incorporated under the laws of Mauritius, challenges aruling dated 21.03.2012 (hereinafter referred to as the ‘impugned ruling’) ofthe Authority for Advance Ruling, (herein after referred to as ‘AAR’) in A.A.R.
CIT vs. Hritnik Exports Pvt. Ltd (Delhi High Court) Sub-section (4) of section 10B stipulated that deduction under that section shall be computed by apportioning the profits of the business of the undertaking in the ratio of turnover to the total turnover.
