ITAT Delhi held that reasons recorded for reopening of assessment u/s 147 of the Income Tax Act doesnt disclose that income has escaped assessment due to failure on the part of the assessee to disclose fully and truly all the material facts and hence assessment order passed thereon are quashed.
ITAT Delhi held that amendments to section 36(1)(va) by Finance Act 2021 are retrospective or prospective is debatable and controversial and any adjustments u/s 143(1) of Income Tax Act by way of intimation, on debatable and controversial issues, is beyond the scope of Section 143(1).
ITAT Delhi held that the trade mark license agreement goes to the root of the matter and hence the same cannot be brushed aside while deciding the matter.
Kamla Devi Vs ITO (ITAT Delhi) In the present case, from the orders of the authorities below, it is clear that the authorities below have treated interest received by the assessee on enhanced compensation u/s 28 of the Land Acquisition Act, 1984 as ‘Income from other sources’ and denied exemption u/s 10(37) of the Act. […]
ITAT Delhi held that penalty under section 271(1)(c) of the Income Tax Act unsustainable as claim of deduction u/s. 80IA(4) already decided in favour of the assessee.
ACIT Vs Exclusive Motors Pvt. Ltd (ITAT Delhi) Undisputedly, the assessing officer has concluded that part of the remittances made by assessee to CCPL towards extended warranty services are in the nature of profit attributable to the PE in India, hence, assessee was required to deduct tax at source on such remittances. He also held […]
DCIT Vs Voestalpine VAE VKN India Pvt. Ltd (ITAT Delhi) The assessee company has claimed an expenditure of Rs.2,41,98,983/- on account R & D Expenditure under the head of manufacturing expenditure. We have perused the details which have been enclosed at page no. 80 of the paper book. The same was also before the revenue […]
Generation of electricity amounts to manufacture or production of any article or they qualifying for deduction u/s 32AC.
Kheer Bhawani Trading P. Ltd Vs ITO (ITAT Delhi) On behalf of the assessee it was submitted that assessee had merely issued preferential shares and as for the purpose of Section 56(2)(viib) of the Act, the Rule 11UA (2) is not applicable. It was submitted that assessee has issued preferential shares and the valuation under […]
ACIT (E) Vs National Association of Software and Service Companies (ITAT Delhi) GTD expenses, Global Trade Development Activity is an on-going program primarily for strengthening the ‘India’ brand, to put and maintain the status of the India IT-BPO industry on the map of the world, by strengthening its credentials in the specific international market, as […]
