ITAT Delhi held In the case of ITO vs. Hepta Developers Pvt. Limited that notice u/s 148 is foundation of the reassessment proceeding. The notice was sent on wrong address while the correct address was available in the return filed by the assessee.
ITAT held In the case of ACIT vs. Raj Kumar Jalan that in view of the proposition laid down by the Honble Delhi high Court in the case of CIT Vs. Bharat Bhusan Jain and others in ITA No.648/09 and 669/2009 etc order dated 08.01.2015
ITAT Delhi has held in the case of ITO, TDS vs. Nokia India Pvt. Ltd that services rendered does not qualify as FTS for technical services under the India Finland Tax Treaty if service provider has not made available to assessee any technical knowledge skill
ACIT vs. R.P.G.Credit & Capital Ltd. (ITAT Delhi) – In course of assessment, AO made addition under Section 68 .CIT (A) remanded matter back for obtaining confirmation of creditors. AO gave a remand report that he was satisfied with confirmation given by creditors and loan appeared to be genuine.
ITAT New Delhi held in Simran Singh Gambhir Vs DDIT International Taxation that if the assessee had disclosed the income by mistake under wrong head of income and that mistake was bonafide then the same could not be treated as an undisclosed income and penalty u/s 271(1)( C) could not be levied.
The assessee has an agricultural land. During A.Y. 2010-11, M/s Indian Oil Coproration Ltd, had laid down the underground pipe-line. The Land of the assessee was in the way of pipe line to be laid down. For digging of land and laying the pipe-line, the Indian Oil Corporation Ltd.
The two appeals filed against the order passed by the Deputy CIT were identical in facts and the issues rose. The core issue involved was the addition made by the AO on account of Arm’s length price determined by Transfer Pricing Officer and confirmed by Dispute Resolution Panel.
First Blue Home Finance Ltd vs DCIT (ITAT Delhi)- The assessee was 100% Indian subsidiary of BHW Holding AG (BHW Germany) and was engaged in the business of providing loans to retail customers for the construction or purchase of residential properties in India.
In the case of Venture Infogain India Pvt. Ltd vs. Dy.Commissioner of Income Tax ITAT has held that provisions the Profit Split Method is applicable mainly in international transactions which are so interrelated that they cannot be evaluated separately
ACIT Vs. DJ Infrastructure Dev Pvt. Ltd. (ITAT DELHI) AO made additions on account of unexplained sources of expenses on the basis of some documents found during search proceedings u/s 132 on Gopal Zarda Group. On seized documents some details of expenses and payment of share premium is mentioned.
