Eminent Computers Pvt. Ltd. Vs ITO (ITAT Delhi) The issue under consideration is whether the re-opening of assessment u/s 147 merely relying upon investigation report is justified in law? ITAT states that the return of income filed by the assessee has also been analyzed with reference to the information received from the Investigation Wing and […]
Boeing India Pvt. Ltd. Vs ACIT (ITAT Delhi) Conclusion: When expatriate employees seconded to taxpayer had worked as employees of the taxpayer company, their salary had been rightly subjected to section 192 and Explanation to section 9(1)(vii) which apparently made it clear that salary would not fall within the expression ‘fee for technical services’ and […]
M/s Aash Trading Company Pvt. Ltd. Vs ITO (ITAT Delhi) We find that AO in the reasons recorded has mentioned that Rs. 75 lacs on account of accommodation entry has been escaped, however, he had issued noticed u/s. 148 of the Act to the assesee. In response to the same, assessee filed the objection which […]
The issue under consideration is whether overdue receivables from AEs is considered as an international transaction? ITAT direct the learned transfer pricing officer to delete the addition on account of interest on overdue receivable from associated enterprise. Accordingly ground of the appeal is allowed.
It was held that the assessment order passed by the Assessing Officer disregarding the instructions of the CBDT are liable to the set aside as AO has not taken prior approval of the authorities mentioned.
Barco Electronic Systems (P) Ltd. Vs DCIT (ITAT Delhi) We have noted that the assessee is not charging interest on overdue debts from the third parties and also the assessee is a debt free company and not paying any interest on funds utilized is business. We have also noted that the assessee company has a […]
Transcend MT Services Pvt. Ltd. Vs DCIT (ITAT Delhi) Assessee has also argued for exclusion of Infosys BPO Ltd, which is having the turnover more than 31.29 times, and TCS E serve Ltd having turnover of 62 times larger than the assessee does. Therefore, for the reasons given by us for exclusion of I gate […]
The issue under consideration is whether addition made by AO for the cash gifts found in search which is received at the time of marriage and anniversary and cash for cancer treatment is justified in law?
Japan International Co-operation Agency (JICA) Vs ACIT (ITAT Delhi) A.O. as well as Ld. CIT(A) have taken a wrong view by holding that the assessee cannot grow tax-free income u/ss 10(34) and 10(35) of the Acts unless additional tax has been paid as per the provisions of Sections 115-0 and 115-R of the Act and […]
The issue under consideration is whether rejection of method of accounting under section 145 without even examination of books of assessee is justified in law?
