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.
ACIT Vs Groz Engineering Tools Pvt. Ltd. (ITAT Delhi) Non-residents have rendered the services outside India and have been paid in foreign currency. Therefore, no income accrues or arises in India. These nonresidents do not have any PE or business connection in India which is not doubted by the AO. Further, the Assessing Officer has […]
Receipts from sale of scrap being part and parcel of the activities and being approximate thereto would also be within the ambit of gains derived from industrial undertaking for the purposes of computing deduction u/s 80IB
Education cess was an allowable deduction while computing the income under the head profits and gains from business or profession as it did not fall within section 40(a)(ii).
Universal Buildrise Private Limited Vs ITO (ITAT Delhi) M/S. Universal Buildrise Private Limited (Appellant) filed an appeal against Order dated September 30, 2019 of the Ld. CIT(A)-9, New Delhi, relating to the Assessment Year (AY) 2016-2017. The Appellant filed its return of income declaring loss and paid taxes on book profit under Minimum Alternate Tax […]
On the basis of incriminating material found, once reassessment proceedings was initiated on the basis of incriminating material found in the search of 3rd party then the provisions of section 153C of the I.T. Act were applicable which exclude the application of section 147 and 148 of the I.T. Act and notice u/s. 148 of the Act and proceeding u/s. 147 are illegal and void ab initio
