Santosh Mohanlal Rathi Vs DCIT (ITAT Pune) ITAT followed Hon’ble Bombay High Court decision in the case of M/s. Nirved Traders Pvt. Ltd., Vs. DCIT (ITA No.149/2017 dated 23.04.2019) wherein the Jurisdictional High Court held that the disallowance under Section 14A of the Act read with Rule 8D(2) of the Rules cannot exceed the Assessee’s […]
Kachhi Heritage Vs ACIT (ITAT Pune) Grounds of Appeal 1. On the facts and in the circumstances of the case and in law the Learned Assessing Officer erred in treating the status of the partnership firm as AOP for the reason that partnership deed is executed on an inadequate stamp paper. Your appellant submits that […]
ACIT Vs Finolex Cables Limited (ITAT Pune) The solitary issue involved in the appeal of the Revenue for A.Y. 2012-13 relating to the assessee‟s claim for deduction u/s 80IC of the Act in respect of sale of scrap is squarely covered in favour of the assessee by various decisions of Tribunal rendered in assessee‟s own […]
Rajesh Madanmohan Chaudhary Vs ITO (ITAT Pune) The assessee in the present case is an individual who is a partner in eight partnership firms. The return of income for the year under consideration was filed by him on 17.10.2016 declaring a loss of Rs.20,74,862/-. During the course of assessment proceedings it was noticed by the […]
ACIT Vs Inox Air Products Private Limited (ITAT Pune) The only issue raised in the assessee’s appeal is against the direction of the ld. CIT(A) for reducing the amount of subsidy from the value of assets for the purpose of granting depreciation. From Explanation 10 to section 43(1) of the Act it is immensely clear […]
No transfer pricing addition in respect of international transaction of payment of Regional Service Charges pertaining to five intra-group services could be made because even if presume that the comparable uncontrolled transaction was at zero mark-up, still the value of the international transaction was within the notified tolerance range.
Aesseal India Pvt. Ltd. Vs ITO (ITAT Pune) The only issue that arises for our consideration is whether the loss arising out of reinstatement of the ECB loan as on date of balance sheet can be added to the actual cost of asset for the purpose of determining the actual cost u/s 43A of the […]
The issue under consideration is whether the addition made by AO u/s 14A read with rule 8D is justified in law? Respectfully following the precedent, ITAT set-aside the impugned order on this score and order to delete the disallowance.
The issue under consideration is whether CIT(A) is correct in confirming the disallowance made by the Assessing Officer u/s.14A read with Rule 8D(2) of the Income Tax Rules, 1962?
DCIT Vs Sheth & Sura Engineers Private Ltd. (ITAT Pune) It is an undisputed fact that the entire turnover of the assessee is exclusively from Government Department and the said turnover has not been disputed by the Assessing Officer. The Assessing Officer has also not considered the debtors of other divisions and only considered debtors […]
