ITAT had held that there is no principal-agent relationship between the bank issuing the bank guaranee of the assessee. The ITAT Mumbai Bench had further noted that while it is termed as |guarantee commission|, the same is not in the nature of commission
M/s Hero Moto Corp Ltd. Vs DCIT (ITAT Delhi) As regards to Ground, relating to disallowance of cost of scrap material amounting to Rs.6.34 lacs, it can be seen that in the course of the business of manufacturing, the process generates some scrap on account of rejection of components, obsolescence of components, etc. In the […]
It is seen that the company has completed full-length animated commercial film during the year under consideration. We note that no separate revenue and expenditure on this activity of making animated film is reported in the Annual Report. Since the activity of making animated film is functionally different from the activity of software development services and thus the segment of ‘software development and services’ of the company, cannot be compared with the functions of the assessee.
M/s. Commitment Mortality Vision Education Society Vs ACIT (ITAT Delhi) In the instant case by way of collusion between the FIITJEE Group and the assessee, the funds have been given to the Group entities in the name of disbursement of scholarship etc. This collusion is evident from the statement of Sh. Aseem Gupta as how […]
Loesche India case: it is not necessary that all the payments/expenditure incurred by the assessee should have direct bearing on earning of income, but some payments are also made under certain business expediency
Moti Adhesives P. ltd. Vs ITO (ITAT Delhi) Mere non production of Director of said share holder company cannot justify adverse inference u/s 68 of the Act. Even if there was any doubt if any regarding the creditworthiness of the share applicants was still subsisting, then AO should have made enquiries from the AO of […]
ACIT Vs Ravnet Solutions (P.) Ltd. (ITAT Delhi) Where assessee, in receipt of share capital, had established onus cast on it to explain identity and creditworthiness of subscribers and genuineness of impugned share transactions by filing evidences such as copies of confirmations, ITRs, PANs and bank statements, etc. AO was not justified in making addition […]
It is simply stated in the application for condonation of delay that due to time barring assessment, the impugned order was overlooked and got barred by limitation.
Moreover, the change /lack of staff with the assessee-organization is not found substantiated by any evidence on record and such a reason, in our considered opinion, does not constitute to be a reasonable cause to file the TDS statements with such an inordinate delay.
Expenditure incurred on the software is eligible for depreciation @60%, depreciation on the block of assets of website development cost eligible @ 60%: Re: appeal A.Y. 2006-07 of Make My Trip (India) Pvt. Ltd.
