AO admitted that the entire amount which was added to income of assessee on protective basis was already assessed in the hands of the overseas companies on substantive basis
On the facts and circumstanced of the case, the learned Commissioner (Appeals) has erred in law in deleting the addition of Rs. 2,21,09,600 holding that the provision of section 50C of the Income Tax Act, 1961 cannot be invoked in this case when there was a transfer of immovable property in view of the provisions of section 2(47)(vi) of the Income Tax Act, 1961
1. On the facts and circumstances of the case and in law, the Ld. CIT(A) has erred in holding that Rule 8D cannot be invoked in the case of the assessee and in directing the A.O. to delete the addition of Rs.3,55,234/- made u/s 14A r.w.Rule 8D.
These two appeals filed by the assessee relate to the assessment years 2012-13 & 2013-14. Since common issue is raised in both the appeals, we are, therefore, proceeding to dispose them off by this consolidated order for the sake of convenience.
Dy. DIT (IT) Vs weatherford Oil Tools (ME) Ltd. (ITAT Delhi) On Issue relating to the service tax, learned AR placed reliance on the decision of the Hon’ble Jurisdiction High Court in the case of CIT vs Mitchell Drilling International P. Ltd. 380 ITR 130 in support of his contention that the service-tax being statutory […]
Delhi ITAT held that mere entry in the books of accounts and classifying the said payment as capital, i.e., it has been capitalised in the books will not at all be determinative as it has to be seen on the facts whether such a payment or expenditure falls in the capital filed or revenue field.
Maruti Suzuki India Ltd. Vs ACIT (ITAT Delhi) The royalty paid to Suzuki Motor Corporation Japan by Maruti Suzuki India Ltd. for the use of licensed information held to be revenue expenditure
While hearing the case of Subodh Gupta vs Commissioner of Income Tax (CIT), Delhi bench of Income Tax Appellate Tribunal (ITAT) recently held that gift received by Hindu Undivided Family (HUF) from the mother of Karta would attract Income Tax.
Whether the observations of Honble DRP is right in directing the TPO to give working capital adjustment [using OCED methodology given in Annexure to chapter – 3 and applying SBI Prime Lending Rate (as on 30th June of the relevant financial year) as the interest rate] against the TPO order dated 16.01.2014 passed u/s 92CA(3) for A.Y. 2010-11.
Delhi ITAT has in the case of Krishan Kumar v/s ITO in ITA No. 3985/Del/2017 has quashed the reassessment proceedings as there was no nexus between reasons recorded and addition made.
