section 143(3) - Page 66

Assessment order passed u/s 143(3) beyond time limit prescribed u/s 153 is time barred

ACIT Vs Essel Corporate Resources Pvt. Ltd. (ITAT Mumbai)

ITAT Mumbai held that assessment order passed u/s 143(3) beyond time limit prescribed under section 153 of the Income Tax Act is time barred and bad in law....

Revisional jurisdiction u/s 263 not invocable merely because PCIT may entertain different view

Cricket Club of India Pvt. Ltd. Vs PCIT (ITAT Mumbai)

ITAT Mumbai held that AO took the plausible view of granting the benefit of mutuality after due application of mind. Accordingly, revisional jurisdiction u/s 263 cannot be invoked merely because PCIT may entertain a different view in the matter....

Reopening of assessment based on mere change of opinion is unsustainable

Glen Propbuild Private Limited Vs DCIT (ITAT Delhi)

ITAT Delhi held that proviso to Section 147 of the Income Tax Act gets applicable as reopening of assessment is initiated after four years of original assessment. Accordingly, re-opening of assessment based on mere change of opinion is unsustainable....

Article 265 of the Constitution mandates refund of excess Income tax paid

Young Women’s Christian Association of Delhi Vs ITO (ITAT Delhi)

ITAT Delhi held that Article 265 of the Constitution mandates that no tax shall be levied or collected except by authority of law. If tax has been paid in excess, same has to be refunded to the assessee....

Rent including service tax paid for the business purpose is allowable u/s 30

Ultimate Fashion Maker Ltd. Vs ACIT (ITAT Delhi)

ITAT Delhi held that rent including service tax on rent paid for the purpose of business is allowable under section 30 of the Income Tax Act....

Penalty u/s 271(1)(c) not leviable as error pointed out by AO was corrected before passing of order

PCIT Vs National Textiles Corporation Ltd. (Delhi High Court)

Delhi High Court held that penalty under section 271(1)(c) of the Income Tax Act not leviable as error pointed out by AO was corrected by the assessee before passing of the assessment order....

Indexed cost of development not allowed on failure to substantiate the claim

Yashpalsingh Surindersingh Matharu Vs ITO (ITAT Pune)

ITAT Pune held that claim of indexed cost of development not acceptable as assessee failed to furnish any evidence towards the same....

Section 40A(3) not applies to cash payments deposited in bank account of payee

Abhishek Saha Vs ACIT (ITAT Kolkata)

ITAT Kolkata held that provisions of section 40A(3) of the Income Tax Act doesn’t apply to cash payments when ultimately the amount is deposited in the bank account of the payee....

Deduction u/s 10B available against interest on bank deposits, receipts of subsidy and insurance claim

Picric Limited Vs ITO (ITAT Delhi)

ITAT Delhi held that interest on bank deposits, receipts of subsidy and insurance claim are eligible to be included in profits of 100% export oriented unit for purpose of claiming deduction under section 10B of the Income Tax Act....

Borrowing funds at higher rate & lending to director shows diversion of funds for non-business purpose

Asuda Holdings Private Limited Vs CIT (ITAT Mumbai)

Asuda Holdings Private Limited Vs CIT (ITAT Mumbai) ITAT Mumbai held that there is a clear diversion of funds for non-business purpose as funds are borrowed @18% and lended the same to one of its directors at 13.5%. Accordingly, disallowance under section 36(1)(iii) sustained. Facts- AO observed that assessee has taken loan from M/s. Elev...

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