Omkam developers Ltd. Vs ITO (ITAT Delhi) 1. The reasons recorded are based on suspicion, which is evident from the words used in reasons recorded, i.e., “it appears that assessee M/s Omkam Developers Ltd. has received bogus share capital/share premium to the tune of ₹ 1.93 Crores. 2. The Assessing Officer has just accepted the […]
ITO Vs Nabinagar Power Generating Co. Pvt. Ltd. (ITAT Delhi) No addition on account of interest income as same was inextricably linked with setting up of power plant and to be capitalized Conclusion: Since the work of construction of the power plant was under progress, interest incomes are also inextricably linked with the setting up […]
Airports Authority of India Vs ITO(TDS) (ITAT Delhi) Conclusion: TDS under section 195 was not applicable on payments made by company to the Federal Aviation Administration, USA (FAA), for providing technical assistance to AAI by way of providing its personnel and meeting on ATFM requirements and assisting AAI in connection with ATFM by development of […]
Air India Limited Vs ITO (ITAT Delhi) Undisputedly, the dispute in the instant appeals is qua applying the TDS rate at 12% or 10% on transfer between ELFC and the assessee for taking an engine on lease under an Agreement. It is also not in dispute that ELFC, the lessor is a foreign company having […]
Merely because the some Directors did not appear in the case of assessee would not be a ground to have an adverse inference against the assessee, therefore, there was no justification to sustain the addition of Rs.45 lakhs under section 68 and addition of Rs.90,000/- under section 69C.
Arpit Goel Vs ITO (ITAT Delhi) 1. Assessing Officer is not suppose to arrive at the final conclusion. He is supposed to reach at a reasonable belief, which a prudent man will arrive at, that the income has escaped assessment. It has to be a prima facie case regarding escapement of income. 2. AO is […]
Renu Proptech Pvt Ltd. Vs ACIT (ITAT Delhi) Considering the plethora of documentary evidences, we find that not only the assessee has established the source of the creditor, but it has also furnished documentary evidences to show the’ source of source’. We find that the AO, while making addition, has made general observations relating to […]
DCIT Vs M/s Interarch Building Products (P) Ltd. (ITAT Delhi) The relevant part of the order of the ld. CIT (A) on this issue pertaining to payments made to Mr . Arvind Nanda, with regard to the vehicle purchase, payment made to M/s Intertec on account of job work and the rental payments has been […]
New Delhi Tyre House Vs ACIT (ITAT Delhi) In this case a Ground is on account of confirmation of disallowances out of telephone tours, and other expenses including depreciation on the car stating that involvement of the personal element of the partners of the firm cannot be ruled out. Both the lower authorities have confirmed […]
Symantec Asia Pacific Pte. Ltd. Vs DCIT (ITAT Delhi) The Assessing Officer raised a query that the consideration amounting to Rs.242,52,89,282/- on sale of licence software should be treated as receipts received on account of sale of licence software as royalty. The issue of software income is not a royalty income is settled by the […]