As regards to the validity of the reassessment proceedings under section 147 r.w.s 148 of the Act, it is not in dispute that the A.O. is required to get the approval of the competent authority i.e; JCIT in the present case. JCIT mentioned as under: Yes, it is a fit case to issue notice under section 148 of the Income Tax Act.
Sh. Prem Pal Gandhi Vs ACIT (ITAT Amritsar) The appellant objected to the levy of penalty as bad in law. He challenged that the AO has not mentioned under which limbs of section 27 1(1)(c) of the Act, whether for concealment of income or furnishing of inaccurate particulars, the penalty was initiated. Thus, He has […]
Shaheed Bhagat Singh Educational Society Vs CIT(Exemption) (ITAT Amritsar) It is not obligatory for the assessee for maintain dissolution clause which will not be the issue for rejection of registration u/s 12A of the Act. Accordingly the registration U/s 12A could not be denied to the assessee-society for non maintain the dissolution clause. Facts- The […]
J & K Tourism Development Corporation Ltd. Vs ACIT (ITAT Amritsar) No disallowance can be made that the payment to the employee’s contribution to PF and ESI paid by the assessee before the due date of filing of return of income u/s. 139(1). Accordingly, we hold that no disallowance can be made in the assessment […]
Rajdhani Transport Company Pvt. Ltd. Vs PCIT (ITAT Amritsar) In this case Section 263 order was passed only on the basis of the non-appearance of assessee and non submission of the document during the proceeding. Section 263 is moved up by two limbs, one erroneous order and second is prejudicial to the interest of the […]
Held that order of CIT(A) sustained on the issue restricting the disallowance of non-capitalization of interest on bank loan on Plant & Machinery and on account of non-capitalization of interest expenditure on Capital Work in Progress u/s 36(1)(iii) of the Income Tax Act.
Smt. Poonam Mittal Vs ITO (ITAT Amritsar) We find that the AO had invoked his powers u/s.154 of the Act for disallowing u/s.40A(3) of the Act the assessee’s claim for deduction of bonus of Rs.2,47,380/- that was stated to have been paid in cash, i.e., in excess of the prescribed limit of Rs.20,000/-. In our […]
Paradise Rubber Industries Vs PCIT (ITAT Amritsar) Admittedly the present case before us is a case of Limited scrutiny selected for particular points reproduced hereinabove confined to 4 issues. The issue for which the PCIT issued the show cause notice was entirely different than the four issues examined under limited scrutiny by the assessing officer. […]
Vinko Auto Industries Limited Vs DCIT (ITAT Amritsar) Now, coming to the second aspect/determination made by the CIT(A) to the effect that the amendment made in Section 36(1)(va) and 43B of the Act by Finance Act 2021 has to be considered as clarificatory in nature and having retrospective effects, therefore would be applicable to the […]
Ld. CIT(A) did not consider submission of Assessee and wrongly observed in impugned order that appellant has not given any submissions and evidences regarding the disallowance of deduction u/s.80C
