Mitchell Drilling India Private Limited vs. DCIT (ITAT Delhi) It is elementary that the ALP is determined of an `international transaction’, which has been defined in section 92B of the Act. The term `transaction’, for the purposes of the Chapter–X containing transfer pricing provisions, has been defined in clause (v) of section 92F to include an […]
There is a mistake of getting the information through AIR which was collected by the appellant’s AR from bank. The transaction reported in the AIR was wrongly reported by the department. The AO should inform DGIT(System) to verify such information from the department server and correct it in future.
When admittedly there is no capital creation with the loan facilities availed of by the assessee, the working capital overdraft facility cannot be kept under the category of capital expenses, rather working capital overdraft facility is oftenly used to run day-to-day business
DCIT(E) Vs GS 1 India Assessee is a society involved in importing, developing and distributing of Bar code technology to be used by various manufacturers and industries which is for the general benefit of public at large. However, during the scrutiny of the return of income of the assessee for the AY 2011-12, AO made […]
ITO Vs M/s. Necleus Steel Private Limited (ITAT Delhi) In this case, assessee received an amount of Rs.67.50 crores from M/s. Unitech Ltd., as advance against the sale of the property. The assessee filed confirmation from M/s. Unitech Ltd., along with its bank statement and acknowledgment of filing of the ITR with balance sheet. The […]
Zion Promoters & Developers (P) Ltd. Vs Addl. CIT (ITAT Delhi) The investment in the share of the assessee company by the above five companies whose directors appeared before the Assessing Officer and whose statements were recorded and full details were filed substantiating the identity and creditworthiness of the investor companies and the genuineness of […]
Axis Risk Consulting Services Private Limited. Vs DCIT (ITAT Delhi) the only dispute before us is with regard to the adjustment by way of imputing interest @ 17.22% by the TPO on account of receivables from the AE. Here in this case, it is an undisputed fact that the assessee has also rendered similar services […]
The action of the lower authorities in not following the case laws on the issue and in spite of legal precedents, still not quashing the penalty of Rs. 2,22,240/- is unjust, illegal, arbitrary, illusory and against the facts of the case and thus deserves to be deleted.
Interest received from debtors for late payment of sale proceeds partakes the character of sale proceeds, and therefore, assessee was eligible for deduction under section 80-IC in respect of such interest.
Challenging the order of the learned Commissioner of Income-tax (Appeals)-IX, New Delhi (for short hereinafter called as “the learned CIT (A)’) in Appeal No.119 of 2011-12 dated 13.08.2014, assessee preferred this appeal.
