The assessee is a company. It is engaged in the business of corporate and project finance and merchant banking. The assessee had taken premises at Bardy House, Veer Nariman Road, Fort, Mumbai-400 001 on rent. During the previous year, it incurred an expenditure of Rs. 30,94,066/- in connection with renovation of the aforesaid leasehold premises. The assesse
Brief facts of the case are that the assessee received a gift of Rs.30,00,000/- from Mrs. Chandra Hingorani. The genuineness of the gift was examined by the Assessing Officer by considering the various documents including taking statements of the assessee which was recorded on 19.12.2006.
The assessee maintained regular books of account following recognized method of accounting. The assessee has shown 10.22% of G.P. for the year under consideration as against 6.78% GP of last year. Search and seizure actions were carried out on 14.6.2006.
It has been held by various judicial pronouncements that unless proper method is followed, comparables are chosen and selected after doing a proper FAR study as well as adjustments are made to the extent possible it would be unfair to summarily reject the transfer pricing analysis made by the assessee
The AO further made a disallowance of a deduction of Rs.6,94,02,867/- u/s 40(a). The assessee claimed that certain disallowances were made for expenditure in the earlier years in the case of KEC Infrastructure Ltd. and as the payments of these disallowed expenditure were made during the year, the assessee claims that the same should be allowed in its han
The assessee in the present case is an investment company which filed its return of income for the year under consideration on 29.10.04 declaring total income of Rs. 5,03,38,480/-. The said return filed by the assessee was selected for scrutiny assessment and in the assessment completed vide an order dated 29.9.2006 passed u/s 143(3), the total income of the assessee was computed by the AO.
The words other right of occupancy appearing in the Explanation 1 of section 32(1) should be construed ejusdem generis with the word lease and if that is so, the right of occupancy should be of such a nature that the assessee should possess an interest in the property and the occupancy must be referable to that interest
During the year, the assessee has shown export sale of polished diamonds and claimed deduction u/s. 80HHC. The assessee also filed an Audit Report in the Form No. 3CEB. The Assessing Officer referred the case to the Transfer Pricing Officer (TPO) for determination of Arms Length Price (ALP) u/s. 92CA(3).
The facts of the case are that the assessee is a Singapore based company engaged in the business of acquiring television programs, motion pictures and sports events and exhibiting the same on its television channels from Singapore. The assessee is a tax resident of Singapore in terms of Article 4 of the India Singapore Tax Treaty.
It was held that transfer of development rights does amount to transfer of land or building and therefore s. 50C is applicable is applicable because u/s 2(47)(v) the giving of possession in part performance of a contract as pers. 53A of the Transfer of property Act is deemed to be a transfer.
