Income Tax Judgements

confirming the disallowance of interest of Rs. 32,30,685/-. The basis for the same, the reasons and also the working of the disallowance are in correct and improper.” By order dated 16.4.2009 the aforesaid ground of appeal was dismissed by the T

These two companies entered into a joint venture agreement on 14th July, 2003 for setting up a project in the State of Mizoram. After sometime, the company pulled out of it. They entered into a different relationship. The petitioning creditor agreed,

From a rending of sub-section (1) of section 263, it is clear that the power of suo motu revision can be exercised by the Commissioner only if, on examination of the records of any proceedings under this Act, he considers that any order passed therei

In this appeal the assessee has raised various grounds, but only dispute is regarding the confirmation of levy of penalty u/s.271(1)(c) of the I.T. Act. The assessee has filed an appeal in the name of ‘Dimples Cine Advertising Pvt. Ltd.’, whereas the

Briefly stated facts of the case are that the assessee paid a sum of Rs.9,54,684/- to a foreign bank without deduction of tax at source. In the audit report, it was mentioned that it was a usance interest paid under the letter of credit and hence not

After hearing both the parties, we find that during assessment proceedings the AO noticed that the assessee has declared sales figure of Rs.1,34,45,538/-.The assessee was asked to file details of the sales and labour charges which were accordingly fu

On the facts and in the circumstances of the case and in law, the Ld. CIT(Appeals) erred in holding that the assessee branch is not the PE in respect of the business done out of the supplies made by foreign principal and accordingly, its business pro

After considering the rival submissions and perusing the relevant material on record, it is observed that similar disallowance was made by the AO in the immediately preceding assessment year i.e. 2005-06. The Tribunal, vide its order dated 31-01-2012

At the very outset, the ld. counsel for the assessee contended that the AO passed order u/s.195(2) treating the assessee as in default by considering the price of the product as fees for technical services. He took us through the impugned order in wh

The CIT thereafter issued notice dated 24.2.2009 under Section 263 of the Income Tax Act, 1961 (“Act” for short) recording the following reasons: “From the computation of income filed with the return, it appears that this profit on sale of proper