For the condonation of the delay, the assessee has to show that there must be a sufficient cause to condone the delay. In this case, the assessee himself decided as per his affidavit not to go to his house knowingly that there must be an assessment order. No one is prevented the assessee to go to his house therefore, we are of the opinion that there is no sufficient cause to condone delay. Accordingly, the appeals filed by the assessee are dismissed.
Jayaseelan Vs ITO (ITAT Chennai) Shri Jayaseelan (the Appellant) has filed the current appeal being aggrieved against the order dated March 5, 2018 passed by the ld. Commissioner of Income Tax (Appeals) (the CIT(A)) for the assessment year 2014-15 wherein the claim of the Appellant claiming benefit under section 54 of the Income Tax Act,1961 […]
In so far as the certificate issued by the Tehsildar is concerned which is at page No.1A of the paper book, it does not show that from the Chidambaram how it comes to 8.5 K.M and apart from that in our view the Tehsildar is not a competent person to decide the distance.
Sak Industries Pvt. Ltd. Vs DCIT (ITAT Chennai) We find that the assessee has purchased 1,25,000/- equity shares of ING Vysya Bank during the month of January and February, 2009 and subsequently during the month of September, 2009 all the shares are sold. The assessee also shows the above transaction in its books of accounts […]
Increase in brand value due to use of foreign AEs brand name in Taxpayer’s products cannot be considered as provision of services, as per international transaction definition u/s 92B of the Income Tax Act, 1961.
Disallowances u/s.14A could not exceed amount of exempt income, therefore, AO was directed to restrict disallowances u/s.14A to the extent of exempt income earned for the impugned assessment year.
Additions made by AO was not only on the basis of sworn statement but also on the basis other evidences collected during the course of search including discrepancies in books of accounts regarding accounting of bogus purchases therefore, there was no merit in arguments of assessee that AO had made additions towards alleged purchases only on the basis of statement recorded from those parties without further evidences.
ACIT Vs CMG Steels Pvt. Ltd. (ITAT Chennai) Facts already disclosed in return of income cannot constitute incriminating material found during search. Also held cross examination importance when requested without which addition becomes invalid In the present case, on perusal of facts available on record, we find that the AO has made additions towards unsecured […]
Once an assessee discharged its burden, then burden shifts to AO to prove otherwise that said transaction was nothing but undisclosed income of the assessee. In this case, AO had not brought on record any evidence to prove that said sum was undisclosed income of assessee. Therefore, AO was completely erred in making additions towards unsecured loans received from three companies of assessee group.
In best judgment assessment, AO had to bring on record certain material with regard to rate of profit admitted for estimation of profit with some comparable cases of similar nature or profit declared in similar industry