19. It is true that attaching the properties of an assessee even before the crystlisation of the demand is a drastic step and has to be exercised only in extreme circumstances. Whether extreme circumstances existed in the present case so as to levy provisional attachment under section 281B of the Act is the question. 20. In the present case, the incriminating documents seized during the course of search and seizure
8.3 It cannot be disputed and it is not the case of either side that the reasons extracted hereinabove did not precede the issuance of notice under Section 148(1) of the Act. The requirement for recordal of reasons by the Assessing Officer before issuing a notice is provided for under sub-section (2) of Section 148 of the Act. 8.4 A perusal of the reasons would thus show that the Assessing Officer was
6.1 The main question before us for decision is whether the interest income could be treated as “business income” or “income from other sources”. The answer to this question has to depend on how the interest income derived by the assessee. No doubt, normally, on the placing of funds in banks on short-term or long-term deposits the interest income derived from those sources would be “income from other sources”
6. We have heard the rival submissions and perused the orders of the lower authorities and the material available on record. In the instant case it is observed that interest expenditure claimed by the assessee at an amount of Rs. 27.90 lacs was disallowed by the Assessing Officer which was restricted by the Commissioner (Appeals) to Rs. 27.75 lacs being net amount of interest paid by the assessee
14.2 After considering the rival submissions in the light of the material placed before us and the precedents relied upon it is obvious that sub-sections (1) and (1A) of section 201 do not prescribe any time limit for the initiation of the proceedings or the passing of the order. We find that for the most of the actions under the Act, the particular time limit has been given for the commencement and completion of the proceedings
The assessee sold valve actuators. At the time of sale, the assessee provided standard warranty that if the product was defective within the stated period, the product would be rectified or replaced free of charge. For AY 1991-92, the assessee made a provision for warranty at Rs.10,18,800 at the rate of 1.5% of the turnover. As the actual expenditure was only Rs. 5,18,554, the excess provision of Rs.5,00,246
Chandrakant H. Shah v. ITO (ITAT Mumbai) In a first-of-its-kind judgement, the ITAT Mumbai recently ruled that a recipient of an interest-free loan from a non-relative is not liable to pay tax. The judgement will come as a major relief for people who borrow money from friends and colleagues and latter grapple with notices from tax authorities.
In October 2007, Disciplinary proceedings were initiated against two partners of M/s Pricewaterhouse (PWC) for alleged professional and other misconduct in conducting the statutory audit of Global Trust Bank. The proceedings were based on the findings in the Special Audit report and the Annual Financial Inspection of the RBI. Though several hearings were conducted by the Disciplinary Committee,
7. Under section 12AA1(a) of the Act, the CIT is empowered to call for information to satisfy himself about the genuineness of activities of trust /institution. The Commissioner may make such enquiries as he thinks fit for the purpose. Under section 12AA1(b) of the Act, after having satisfied about the objects of Trust/institution and genuineness of its activities,
19. One of the things which is clearly discernable from the facts of this case is that so far as the year before us is concerned, which was incidentally first full year of assessee’s operations, the import content of the raw materials was as high at 98.95%. This is materially different from the import content of the raw material in the cases of the comparables selected by the revenue authorities.
