The contention of the assessee is that since final consideration was paid and the possession of flat was received within a period of one year prior to the date of transfer of capital asset, the same should be considered as the date of purchase. Whereas, the stand of Department is that the date of execution of agreement for purchase of flat should be considered as the date of purchase.
Revised enhanced minimum threshold limit of tax effect of Rs. 50,00,000 vide recent CBDT Circular No. 17/2-19, dt. 8-8-2019 was applicable not only for appeals to be filed by revenue in future; but also for appeals already filed by revenue in ITAT. Accordingly, all existing appeals in ITAT, having tax effect below revised/enhanced limit of Rs. 50,00,000, had to be treated as withdrawn/not pressed, and therefore, not maintainable.
The issue under consideration is whether CIT(A) is correct by annulling the assessment order on the ground that no notice under section 143(2) was issued before the completion of assessment?
The issue under consideration is whether A.O. is correct in denial of credit of TDS on rental income collected by the appellant under an agreement on behalf of Government?
Harish Chand Ram Kali Charitable Trust Vs ACIT (ITAT Delhi) The issue under consideration is whether the CIT(A) is correct in concluding that the hostel running activity is a business activity? The assessee society was established with the aim to impart education and other charitable activities covered under section 2(15) of The Income Tax Act. […]
Max New York Life Insurance Company Ltd. Vs DCIT (ITAT Delhi) 1. This is an appeal filed by the assessee against the order of the ld CIT (A)-22, New Delhi dated 15.11.2017 for the Assessment Year 2014-15. 2. The assessee has raised the following grounds of appeal:- “1. That on the facts and circumstances of […]
Nirmala Devi Vs ITO (ITAT Delhi) In the given case, the Investigation Directorate, Ahmedabad carried out survey u/s 133(A) to examine the misuse of Client Code Modification for tax evasion. The client code of the assessee was SS 493 & as per the Assessing Officer the error by the operator could be in the form […]
HPL Additive Ltd Vs DCIT (ITAT Delhi) The issue under consideration is whether the addition made by A.O. u/s 41(1) treating the outstanding as cessation of liability is justified in law? During the course of scrutiny assessment proceedings, assessee was asked to furnish complete details of sundry creditors. After perusing the details, AO noticed that […]
The reasons recorded for reopening of the assessee are very foundation of the reassessment proceedings. However, same analogy can also be applied in ongoing ‘Limited Scrutiny’ in which the AO has been directed to examine the only specified limited issues and this stand of the assessee can ignite the litigation.
Comparison of activities undertaken /functions performed was important for determining the comparability between controlled and uncontrolled transactions/entity.
