Income Tax : In the case of Bhuvan Leasing and Infrastructures Vs ITO, ITAT Mumbai has held that where it is the intention of the assessee to l...
Income Tax : In the case of En-Vision Enviro Engineers (P) Ltd. Vs DCIT, it was held that deduction u/s 80IA(4) cannot be disallowed, merely on...
Income Tax : The assessee submitted that he was managing director of SISICOL, which had many deposit schemes and 290 units or branches to aid i...
Income Tax : It would be the proximity of the reasons with the belief of escapement of income, which would be the determinative factor for reop...
Income Tax : There is no dispute about the allowability of expenses. Only dispute is regarding the year of allowability. If the Assessing offic...
In the case of Bhuvan Leasing and Infrastructures Vs ITO, ITAT Mumbai has held that where it is the intention of the assessee to lease out various premises and then sublet the same on leave and licence basis to different parties
In the case of En-Vision Enviro Engineers (P) Ltd. Vs DCIT, it was held that deduction u/s 80IA(4) cannot be disallowed, merely on the ground that the assessee must be owner of the infrastructure facilities and the assess should be a developer and not contractor.
The assessee submitted that he was managing director of SISICOL, which had many deposit schemes and 290 units or branches to aid its operations. He was also a partner of the firm, which entered into an understanding with SISICOL
It would be the proximity of the reasons with the belief of escapement of income, which would be the determinative factor for reopening of the assessment. The remoteness of the reasons would obviate the possibility of a belief and would bring the case in the realm of mere suspicion
There is no dispute about the allowability of expenses. Only dispute is regarding the year of allowability. If the Assessing officer is of the view that the expenses are pertaining to the prior, the same are required to be considered for the prior and allowed in that year.
The court considered the reasoning of the Revenue and held, firstly as the arrangement was in place with the UTI (which had to purchase the NCDs at Rs. 389/- per NCD), the assessee gave effect to it (the arrangement). UTI paid Rs. 389/- per debenture to JISCO
The reserve, which is required to be created under Section 45-IC, is out of the profits earned by a non-banking financial institution. It is not an amount diverted at source by overriding title. The Reserve Bank of India Act, 1934 can permit appropriation in respect of the said reserve.
The Revenue’s argument seems plausible and even logical because the Commissioner or a Chief Commissioner is unarguably ranked higher in authority than a Joint Commissioner. Yet at the same time
In the present case, there is no doubt at all that the assessee cooperated and appeared both in the assessment as well as reassessment proceedings. Therefore, it had deemed notice of the re-assessment proceedings.
In the present instance, the AO apparently had the books and all the relevant information pertaining to the share applicants. CIT v. Lovely Exports (P) Ltd. 2008 (216) CTR (SC) 195 directs that whilst the initial onus to prove the identity of a third party,