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Income Tax : ITAT Ahmedabad held that AO had no jurisdiction to initiate proceedings u/s. 153C of the Income Tax Act beyond permissible period ...
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The issue under consideration is whether the architectural services provided to Singapore Entity taxable at 10% or 20% when the benefit of Double Taxation Avoidance Agreement (DTAA) is available?
whether addition made by AO u/s 68 as Unaccounted/Unexplained Income by treating the Long Term Capital Gain as Manipulated Transaction is justified in Law?
The issue under consideration is whether order passed by the AO held that the draft order framed under Section 144C(1) of the Income Tax Act is in the name of a non-existent company is sustainable in law?
The issue under consideration is whether transfer pricing adjustment as notional interest and charging it to tax, disregarding the provisions of Article 11 of India Cyprus DTAA is justified in law?
The issue under consideration is whether the issue of notice u/s 153C instead of section 153A is considered as valid assessment or not?
ITAT states that, anyhow disallowing 10% of the expenditure on the ground that profit leakage has to be plugged cannot be supported. Keeping in view the facts and circumstances of the case, some disallowance of a random amount of 5 lakhs, in our view, would meet the end of justice. In the result, the balance disallowance is deleted and the appeal of the assessee is allowed in part.
ACIT Vs Volvo Auto (India) Private Limited (ITAT Delhi) The issue under consideration is whether CIT(A)is correct in deleting the addition made on application of CUP method for determination of ALP of international transactions by the A.O.? ITAT states that, the AO’s observation that this expenditure has been debited to the profit and loss account […]
The issue under consideration is whether the penalty notice u/s 271(1)(c) issued to the assessee who has taxed his income as per provision of section 115JB pr 115JC is justified in law?
The issue under consideration is whether disallowance of relocation expenses u/s 40(a)(i) of the Act and non granting of tax deducted at source with respect to that expense is justified in law?
In the instant case, the assessee in the year under consideration has claimed an expense under the head prior period item in its profit and loss account. Such prior period item was representing the excise duty with respect to waste i.e. Spent Earth generated during the manufacturing process. The assessee during the assessment proceedings admitted that such expenses pertains to the earlier year but the same is allowable on payment basis under section 43B of the Act.
