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In the petition for admission of additional evidence it is submitted on behalf of department that the Linkedin Profile of employees of Assessee are available in public domain and down loaded from the web site of internet and the source is indicated against the same.
In the case of ACIT v/s Praveen Kumar there was an addition made on account of unsecured loan and interest paid thereon. All the details were furnished before the A.O in form of account of the creditors along with acknowledgement of their income tax returns and bank statement .But summons issued to lenders were not responded .
If no additions made on grounds set for reasons for reassessment, than no addition can be made on other aspects The legal position is fairly well settled on the issue that in a reassessment proceeding, when no additions are made in respect of the income, purportedly escaping the assessment, set out in the reasons for re-opening the assessment, no other additions can be made either.
Merely because and institution has borrowed funds, one cannot conclude that the objects of such institution cannot be charitable. The assessee may borrow funds for fulfillment of its objects, therefore, we have stated in framing words, the mere facts of borrowing cannot be against the assessee at the stage of grant of registration.
Hon’ble Delhi High court in the case of Dinesh Jain has held that Penalty u/s. 271E is leviable if a person repays any loan, otherwise, than in accordance with provisions of section 269T. As per section 269T no person shall repay the loan otherwise, than by an account payee cheque or account payee bank draft drawn in the name of the person who has made the loan.
The assessing officer is a prospector of the revenue and he is no doubt expected to protect the interests of the revenue zealously, but such zeal has to be tempered with the rules of fair play and an anxiety to ensure that a opportunity is not lost to the assessee to make alternative arrangements for clearing the tax dues, once the stay applications filed under section 220(3) are rejected.
On perusal of the order passed by the Tribunal in case of DCIT Vs. M/s Wockhardt Hospitals Ltd., (supra) it is to be seen that service agreement entered in case of M/s Wockhardt Hospitals Ltd., clearly establishes an employer and employee relationship since Doctors are governed
Held – The assessee trust has taken various steps, including the construction of building and getting the necessary permission and sanction for running the school; so as to bring the school into “existence” during the year, although the school have separate running classes from next
“As evident from a plain look at the ground of appeal, the actual grievance of the appellant is not on merits but on the legal issue regarding limitations on the powers of the CIT(A) on the ground that post 1st June 2001
A bare perusal of the provision contained in Section 153C of the I .T. Act leaves no doubt that, as is provided under Section 158BD, where the Assessing Officer, while proceeding under Section 153A against a person who has been subjected to search and seizure under Section 132(1)
