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Search Assessment u/s.153C is Void If AO’s Satisfaction Not Recorded

Case Name : Ingram Micro (India) Exports Private Limited Vs Dy. Director of Income Tax (ITAT Mumbai)
Appeal Number : ITA Nos. 8133, 8137, 8138, 8136, 8135 & 8132/Mum/2010
Date of Judgement/Order : 21/12/2012
Related Assessment Year : 2002-03 to 2007-08
Courts : All ITAT (14953) ITAT Mumbai (3584)
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Addition u/s. 68 justified if applicants do not respond to summons, despite submission of PAN & bank details

Case Name : Commissioner of Income Tax Vs M/s. N.R. Portfolio Pvt. Ltd. (Delhi High Court)
Appeal Number : ITA Nos. 134/2012
Date of Judgement/Order : 21/12/2012
Related Assessment Year :
Courts : All High Courts (13955) Delhi High Court (3377)
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Reopening justified if Assessee not disclosed in return of income that it was a search case

Case Name : Bipinkumar P. Khandheria, Advocate Vs Deputy Commissioner of Income-Tax (Gujarat High Court)
Appeal Number : Special Civil Application No. 6555 of 2001
Date of Judgement/Order : 14/08/2012
Related Assessment Year :
Courts : All High Courts (13955) Gujarat High Court (1140)
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Oversight/ workload not reasonable cause to condone delay in appeal filing

Case Name : Assistant Commissioner of Income-tax Vs Vimal Mehra (ITAT Delhi)
Appeal Number : IT Appeal No. 1484 (DELHI) of 2012
Date of Judgement/Order : 26/10/2016
Related Assessment Year : 2007-08
Courts : All ITAT (14953) ITAT Delhi (3706)
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Royalties & FTS are liable to tax as per Article 12 of the India-USA treaty only on payment basis

Case Name : Booz. Allen & Hamilton (India) Ltd. Vs Assistant Director of Income-tax (ITAT Mumbai)
Appeal Number : IT Appeal No. 4505 (MUM.) of 2003
Date of Judgement/Order : 21/12/2012
Related Assessment Year : 1998-99
Courts : All ITAT (14953) ITAT Mumbai (3584)
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Penalty justified if Assessee manipulates its accounts so as to reduce its profits

Case Name : Sanghvi Swiss Refills (P.) Ltd. Vs Assistant Commissioner of Income Tax (Bombay High Court)
Appeal Number : IT Appeal No. 250 of 2011
Date of Judgement/Order : 20/11/2012
Related Assessment Year :
Courts : All High Courts (13955) Bombay High Court (1882)
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Treatment of expense should be based on nature & not on assessee’s statement

Case Name : Chamundi Steel Rolling Mills Vs Assistant Commissioner of Income Tax (Madras High Court)
Appeal Number : T.C. (A) No. 2173 of 2006
Date of Judgement/Order : 01/10/2012
Related Assessment Year :
Courts : All High Courts (13955) Madras High Court (1763)
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Losses from share trading through sister concern at a lowest market price are ‘artificial losses’ & not allowable

Case Name : Commissioner of Income Tax Vs Vachanband Investment Ltd. (Delhi High Court)
Appeal Number : IT Appeal No. 84 of 2010
Date of Judgement/Order : 26/09/2012
Related Assessment Year :
Courts : All High Courts (13955) Delhi High Court (3377)
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No penalty U/s. 271D for dealing in cash deposits with rural dwellers, being a reasonable cause for failure

Case Name : Commissioner of Income-tax Vs Sahara India Mutual Benefit Co. Ltd. (Delhi High Court)
Appeal Number : IT Appeal Nos. 846, 848, to 851 & 876 of 2011
Date of Judgement/Order : 20/09/2012
Related Assessment Year :
Courts : All High Courts (13955) Delhi High Court (3377)
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Penalty order quashed by HC as authorities up to ITAT level were not clear about facts

Case Name : Pramod Mittal Vs Commissioner of Income Tax (Delhi High Court)
Appeal Number : IT Appeal No. 67 of 2012
Date of Judgement/Order : 11/10/2012
Related Assessment Year :
Courts : All High Courts (13955) Delhi High Court (3377)
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