ITAT quashed reopening where reasons recorded by the assessing officer produced before the higher authority are quite different and whereas the extract given to the assessee was merely of two paragraphs
The issue which is arising in the present appeal is whether there is DAPE. The Assessing Officer has alleged the existence of DAPE on account of alleged marketing activities undertaken by Indian entity on behalf of the assessee company.
The fact that provision made at the end was reversed in the beginning of next accounting year showed that there was no income accrued. Mere entries in books of account did not establish accrual of income in the hands of payee and hence there was no liability on assessee-company to deduct merely on the provisions made at year end.
Appeal filed by assessee dismissed due to ignorant attitude of the assessee towards appeal.
The issue under consideration is whether the software expenses are allowed as revenue expenditure? Software Expenses incurred for Upgradation are Allowed as Revenue Expenditure.
The issue under consideration is whether the CIT is correct in rejecting the application filed by Bar Council of Delhi seeking registration u/s 12A (a) of the Income Tax Act?
The issue under consideration is whether AO and CIT(A) are correct in disallowing the Business Promotional Expenditure declared by the assessee?
The issue under consideration is whether the stamp duty paid for obtaining the business premises on lease is deductible under section 37 of the Income Tax Act, 1961?
The issue under consideration is whether the depreciation at the rate of 60% will be allowed for computer related software?
Assessee has not furnished before AO all necessary evidence so as to establish that land in question was agricultural land only as per provisions of sec. 2(14)(iii)(b) of I.T. Act.
