It seems CAs are under attack from all parts of the world for good or not so good reasons. Recently CAG in its report Criticised CAs for alleged Mistakes in Tax Audit Report and signing of Tax Audit Reports more than the prescribed limit.
Admittedly the assessment for the year under consideration has been completed on the basis of notice under Section 153C dt. 14.9.2010. Notice has been issued in the name of M/s Image Credit & Portfolio Ltd. That the Hon’ble Delhi High Court
Learned counsel for the assessee submitted that it is a case of frivolous double addition on deliberate misconception of the facts. He took us through the year-end financial statements of the assessee and its computation of income to demonstrate that the impugned addition
It is settled law that that frequency and magnitude of transaction are also important factor to decide whether the transaction is business transaction or investment transaction. Now in our considered opinion, the magnitude of share transaction in this case does call for any enquiry
In sunbeam Auto case Hon’ble Delhi High Court has held that though revision can be made in a case when there is lack of enquiry in the order, however, inadequate inquiries cannot be a basis of revision as it depends on the perception of the officer exercising assessment powers.
We have heard rival submission and perused the material on record. It is not disputed that the assessee had started the business of trading in shares from A.Y. 2007-08. For A.Y. 2007-08, assessee had earned profit of Rs.7,73,143/- which has been declared as “business income”
The only issue here is the addition of Rs.60 lacs made by the Assessing Officer as unexplained credit on account of the share application money. On going through the facts of the case, we notice that assessee has filed the relevant details which it could have filed in support of its contention
The company was incorporated on 24-11-2004 under the Indian Companies Act with the authorized capital of Rs. 2,00,00,000/- being minimum capital for the company obtaining membership of stock broker.
As per provisions of section 132B of the Act the assets seized u/s 132 or requisitioned u/s 132A may be adjusted towards the amount of any “existing liability”. The Explanation 2 attach to section 132B of the Act clarifies that for removal of doubts it is hereby declared that the “existing liability”
In the present case, we are dealing with a situation in which payment has been made to a non-resident taxpayer but the said non-resident taxpayer has taken into account the receipts in question in his business income and has already filed his income tax return under section 139(1)