Akhilesh Kumar Sah

As the issue of allowability of deduction u/s 37(1) of foreign tax credit on which tax credit is not available u/s 90 has been admitted by the Hon’ble Bombay High Court in the case of Tata Sons (supra), the same being a debatable issue, no revisionary proceedings u/s 263 is tenable....

Jefferris India Pvt. Ltd. Vs. ACIT (ITAT Mumbai) When there was no willful concealment and mistake involved human error, penalty under section 271(1)(c ) deleted...

Grundfos Pumpas India case: Where the provision was made on a scientific basis and not on an adhoc estimate, deduction in respect of provision for warranty was allowed...

Where Any Incriminating Material Was Not Found During The Course Of Search, The Completed Assessments Could Not Be Opened: Varun Beverages Appeal...

Lovelock & Lewes  case: Expenditure incurred by the assessee on payment of software licence fees for applications software for the right to use the software for limited/particular period of time held to be revenue expenditure...

He held that the amount in question thus represented provision for meeting unascertained liabilities which was not allowable as deduction in the case of the assessee. He accordingly made a disallowance of Rs. 2,25,01,129/- on account of future development expenses and made addition to that extent to the total income of the assessee in the...

Reopening Of A Completed Assessment Not Allowed On A Issue Which Was Based On Nothing But A Change Of Opinion On The Same Facts And Circumstances Which Were Already In Knowledge Of Income Tax Officer Even During The Original Assessment Proceedings...

Mother Dairy Fruit & Vegetable Pvt. Ltd. Appeal: AO Failed To Establish A Legal Basis For The Addition On Account Of Disallowance Of Interest Expense, When The Assessee Had Not Even Claimed It As Expenditure Or Deduction, Addition Unjustified...

DLF Hotel Holding Case: Interest On Borrowed Funds Allowed As Deduction Under Section 36(1)(iii) Even If Some Of Funds Financed To Subsidiary Companies...

The Bombay Samachar Pvt. Ltd. Case: Where Disallowance Of Remuneration To Directors Is Because Of Loss Shown By The Assessee The Remuneration Cannot Be Disallowed...