Income Tax : In regard to claim of expenditure on Registrar of Companies’ fee for increase in authorized share capital, the HC held that the ...
Income Tax : The ITAT noted that there are three stages in operational business:- (i) setting up; (ii) post setting up but before commencement ...
Income Tax : CIT (Appeals) did not offer any opportunity to the assessee to make submissions with respect to the materials obtained from the su...
Income Tax : The expenses claimed for transportation could not have been a valid ground for rejecting the books of account considering the fact...
Income Tax : Revenue has to be vigilant in issuing notice to the third party under Section 158 BD, immediately after the completion of assessme...
In regard to claim of expenditure on Registrar of Companies’ fee for increase in authorized share capital, the HC held that the same could not be allowed and was also not amortizable under Section 35D (2)(c)(iii) of the Act, not being fee for initial registration of the company.
The ITAT noted that there are three stages in operational business:- (i) setting up; (ii) post setting up but before commencement of business; and (iii) commencement of business and thereafter. In case of a building contractor
CIT (Appeals) did not offer any opportunity to the assessee to make submissions with respect to the materials obtained from the survey and unilaterally rendered findings, CIT (Appeals)’s order was bad for the reason that he did not follow the procedure prescribed by the law.
The expenses claimed for transportation could not have been a valid ground for rejecting the books of account considering the fact that the transport expenses in doubt was just 5.1% of total Transport Expense.
Revenue has to be vigilant in issuing notice to the third party under Section 158 BD, immediately after the completion of assessment of the searched person, this Court is of the opinion that a delay ranging between 10 months of 1 ½ years cannot be considered contemporaneous to assessment proceedings.
The assessee contended that the note was antedated and is accordingly not valid. He tried to substantiate his argument by demonstrating the following: If the satisfaction note was recorded on 29th Aug., 2002
The assessee firm is a builder and developer and is assessed in the status of AOP. During the year under consideration, the assessee was developing a residential project which involved construction of 182 flats. The assessee did not disclose any income out of these projects on the plea that it was following ‘project completion method’ and offered income on these in AY 2010-11
ITAT had given a finding that the services provided to AE, Singapore cannot be equated with the kind of services provided to AE, Germany. Thus by following the order passed by the Tribunal in the hands of the assessee for AY 2006-07, we uphold the order of ld. DRP on this issue. Accordingly, the appeal filed by department is dismissed.
On facts, the Tribunal had clearly stated that the assessee had been in fact supplied the verbatim copy of the reasons, reproducing the same at paragraph 2 (page 2) of its order. The tribunal’s findings appear at paragraph 2.8 of the impugned order.
Whether the transactions between the head office in India and branch office in Canada can be considered as international transactions? The assessee had entered into certain transaction with his branch office in Canada. The AO had taken these transactions also into sweep for the purposes of making the transfer pricing adjustment.
