Goodyear India Ltd. Vs NeAC (ITAT Delhi) Coming to Ground raised by the assessee against the making of adhoc disallowance amounting to Rs.3,52,33,953/- being 30% of the total expenditure of 11,74,46,510/- incurred by the assessee on advertisement and publicity. CIT DR submitted that the AE of the assessee company would certainly be benefitted by expenditure […]
Indo States Exports Vs ACIT (ITAT Delhi) The only effective ground is against the disallowance of Rs.3,01,631/- on account of late payment of employee’s contribution towards EPF and ESI. Ld. Counsel for the assessee submitted that authorities below were not justified in disallowing the claim of the assessee in respect of employee’s contribution. Hon’ble Jurisdictional […]
Jansampark Advertising & Marketing P. Ltd. Vs ITO (ITAT Delhi) Settled position of law as held by the Hon’ble High Court in the case of Haryana Acrylic Manufacturing Co. v. Commissioner of Income Tax 308 ITR 38 [ Delhi] is that the requirement of recording the reasons, communicating the same to the assessee, enabling the […]
Ajay Enterprises Pvt. Ltd. Vs DCIT (ITAT Delhi) The solitary ground raised by the assessee in this appeal pertains to disallowance of Rs. 10,47,025/- incurred by the assessee during the year as ground rent on lease hold properties to L& DO. According to the AO this amount is not allowable u/s 43B of the Income […]
SJM International Ltd. Vs DCIT (ITAT Delhi) The conclusion of the Assessing Officer at the end of the reasons recorded as noted above is contradictory. In the first two lines, the Assessing Officer has recorded the finding that the sum of Rs.2,35,00,000/- has escaped assessment but in the last two lines, he has recorded that […]
ACIT Vs Starwood (M) International Inc. (ITAT Delhi) Conclusion: In present facts of the case, while dismissing Revenue’s appeal, it was held that to prove case under Article 12 of India-US DTAA, no specification was given or limb was satisfied by the Revenue. Further, it was also held that no new facts could be entertained […]
Lakhmi Chand Tejoo Mal Vs ACIT (ITAT Delhi) Applying Deemed Dividend Without Disputing Purpose Of Transaction In Violation To CBDT Circular No. 19/2017 Is Invalid. GIST 1. We have carefully considered the orders of the authorities below and the relevant documents brought to our notice. The undisputed fact is that vide agreement to sell dated […]
Lakhmi Chand Tejoo Mal Vs ACIT (ITAT Delhi) MULTIPLICITY OF ERRORS IN REASONS MAKE REASSESSMENT VOID The ld. counsel for the assessee vehemently stated that 11 entries have been shown in the information and it can be seen that there are repetition of same entries/amounts and the Assessing Officer has, in fact, at para -6 […]
Brace Iron & Steel Pvt. Ltd. Vs Addl. CIT (ITAT Delhi) A.O. disallowed the payment of up-front fee of Rs.1,10,82,175/-on the ground that the assessee was required to pay the same as a lump sum one time non-refundable fee for processing of the loan prior to the execution of the Loan Agreement, therefore, it is […]
Perfect Probuild P. Ltd. Vs DCIT (ITAT Delhi) A reading of section 194C with Explanation (iv) thereof makes it clear that any person responsible for paying any sum to any resident for carrying out the work of advertising, broadcasting and telecasting shall deduct an amount equivalent to 1% where the payment is being made to […]
