ACIT Vs Ankit Nivesh & Management Pvt. Ltd. (ITAT Delhi) In absence of any specific date of handing over of material in the satisfaction note, the date of recording of satisfaction will be taken to be the date of handing over the material. The assessee is engaged in the business of investment and sale purchase […]
Modern Papers Vs ITO (ITAT Delhi) During the assessment proceedings claim of assessee could be considered by way of a simple letter without filing any revised return The assessee is engaged in the business of Agro Chemicals and set up a manufacturing unit in the State of Jammu & Kashmir, which is notified area, entitling […]
Depreciation expense to be considered as operating & revenue generated from non-routine business operations to be considered as non-operating in nature in transfer pricing calculations for taxpayers as well as comparable companies.
Common maintenance charges received from tenants of property were towards maintenance and promotion of common area and the same were business receipts liable to be assessed under the head ‘Income from business’.
In present facts of the case, the Hon’ble Tribunal relied upon the previous Judgments passed in the assesse own case and have observed that agents of the assessee did not have the necessary authority to conclude the contracts of the assessee and, on that premise, it was held that there is no agency PE of assessee in India and therefore Assessee was not taxable in India.
Tech Mahindra Business Services Limited Vs DCIT (ITAT Mumbai) During the course of assessment proceedings, the assessee was asked to furnish the break-up of foreign exchange gain credited in the profit and loss account amounting to Rs.13,31,38,000/- for which deduction u/s.10A of the Act was claimed by the assessee. The assessee was also asked to […]
DSIIDC Ltd. Vs PCIT (ITAT Delhi) It is pertinent to note that the Assessing Officer has raised only a query before completion of assessment u/s 143 (3) relating to claim of 80IA(4). However, the Assessing Officer has not given any cogent finding. Thus, the observation of the Principal Commissioner of Income Tax that the assessment […]
Green Park Estate Pvt. Ltd. Vs ACIT (ITAT Delhi) A perusal of the reasons recorded in the case of the assessee as well as in the case of M/s Green Valley Tower Ltd. are identical on the issue of alleged interest paid on post dated cheuqes. We have also gone through the paper book containing […]
ITAT find that order u/s 263 passed by PCIT dwelled into the issue of re-computation of capital gains which is beyond the mandate of limited scrutiny issued by CBDT. Hence, directions of PCIT are beyond selection criteria of scope of scrutiny for instant year cannot be held to be legally valid.
Internal Comparable Uncontrolled Price Method (CUP) to be preferred as the Most Appropriate Method over External CUP, where direct internal comparable price is available.
