The issue under consideration is whether the issuing notice u/s 153C to the person other than person against whom search is initiated, but without submitting satisfaction note is justified in law?
The issue under consideration is whether the deduction claimed u/s 80HH, 80I and 80IA for production, processing, transmission and distribution of various gases is justified in law?
The issue under consideration is whether the CIT(A) is correct in confirming an addition of by treating sale of land as business income against the appellant’s claim as “Long Term Capital Gain”?
The issue under consideration is whether the addition made u/s 40A(2)(b) in case of estimation of income without doubting expenses incurred by assessee is justified in law?
Bacardi India Pvt. Ltd. Vs ACIT (ITAT Delhi) Under Sections 92B to 92F, the pre-requisite for commencing the TP exercise is to show the existence of an international transaction. The next step is to determine the price of such transaction. The third step would be to determine the ALP by applying one of the five […]
Explore ITAT Delhi’s ruling in American Express India vs DCIT. Key issues: Comparable selection, transfer pricing adjustments, corporate tax matters.
Expenditure incurred on Advertisement, Marketing and Promotion (AMP) for creating market intangibles including brand value in favour of Associated Enterprises was not considered as an international transaction as mere use of brand name or logo owned by the AEs by assessee would not automatically lead to influence that any expenses that assessee incurred towards AMP was only to enhance the brand and there was no cogent material to treat the incurring of AMP expenses as international transactions.
Jai Gopal Sondhi Vs ITO (ITAT Delhi) We note that although the Assessing Officer has levied penalty in all the four cases for non-compliance of statutory notices, all the same he has proceeded to frame the assessment order u/s 143(3) of the Act. We also note that the CIT(A), while dismissing the assessees’ appeals has […]
Surana Enterprises Vs ITO (ITAT Delhi) The issue under consideration is whether the addition made by AO u/s 69C by considering the purchases as Bogus Purchase is justified in law? ITAT states that, in present case, the assessee has shown sales of the goods, or otherwise the goods are lying in the closing stock. If […]
Issue was as regards imposition of penalty under section 271(1)(b) for non-compliance by assessee with respect to statutory notices issued under section 142(1), when assessment was completed under section 143(3).
