ITAT Jaipur held In the case of M/s. Gillette India Ltd. vs. ACIT that the services availed are intra-group services in the nature of Accounting and Financial Reporting Services, Employee services etc. . These are routinely outsourced by no. of companies in India and other countries because of their economic
he barrage of indiscriminate allegations include misuse of official position, corruption, insulting him and son: colluding with retired income tax officers to harm his client so on and so forth. The severity of accusations and fury emerging from their language is highly derogatory, defamatory and contemptuous, sent with a scheme and clear intention to intimidate judicial officers to desist from passing an unfavorable order.
As regards, second issue CIT(A) has rightly adopted the peak credit theory by considering the fact that that there was only rotation of overdraft funds whereby the funds advanced on earlier dates were received back subsequently and there were no fresh deposits.
In the present facts of the Case there are three vital issues in which the Hon’ble Tribunal held that expenses like Telephone expenses, Diwali Expenses, Travelling Expenses, Vehicle Running, Event management Expenses
Discount to distributors by Telecom Company is not in the nature of commission/brokerage and the roaming charges paid to other telecom operators are not in the nature of fee for technical services.
ITAT Jaipur held In the case of Integrated Decisions and Systems (India) Private Limited vs. ITO that these risk adjustments are only theoretically which cannot be quantified in terms of any calculation to conclude the exact adjustment in ALP.
In the case of M/s Sharma East India Hospitals & Medical Research Ltd vs. DCIT, ITAT Jaipur held that disallowance out of unverifiable purchases may be restricted to 15% following the consolidated order in the cases of Sh. Anuj Kumar Varshney and ors. Vs. ITO, ITA No. 187/JP/2012
Hon’ble Delhi ITAT has in the case of ACIT V/s M/s Responsible Builders Pvt. Ltd in ITA No. 2726/Del /2011 has held that it is trite law that in order to determine whether there are reasons to believe that the income got escaped the assessment, one has to look at the reasons recorded by the Assessing Officer before the issuance of notice under Section 148 of the Act.
The learned counsel for the assessee contends that the concerned Chartered Accountant has admitted that the impugned orders of CIT(A) were handed over to him by the assessee in the first week of April, 2011 for filing the appeals before ITAT.
Coming to a concomitant situation that if booking of flats does not tantamount to ownership of the house then how come the assessee claim that by booking a flat it has acquired ‘new house’ and becomes entitle for this exemption.
