Judgements by CHEZHIYAN

Merely because tax on income was paid for some assessment years would not estop the non-resident assessee from contending that its income is not liable to tax in India.

The head note to section 80HHC refers to deduction in respect of profits retained for export business, it is not profits retained from export business; in the matter of determining the quantum of deduction, under section 80HHC(3) the “principle of pr

For qualifying exemption under section 54F, assessee’s ownership and domain over the asset is a must right from the sale of original asset till the purchase and/or construction of the residential house i.e., the “new asset”

Section 9, of the Income-tax Act, 1961, read with article 12, of the Direct Tax Avoidance Agreement between India and USA - Income - Deemed to accrue or arise in India - Applicant is an Indian company and is mainly engaged in business of providing ca

Thus, in our view, the provisions of section 69 cannot be said to be attracted to the price of stock in question. Though, not necessary, but still it may be considered and observed, that during the relevant year, the entire income of the assessee wa

Effect of non-consideration of the application for registration within the time fixed by section 12AA(2) would be a deemed grant of registration

The basis for initiating the reassessment proceedings is to be judged solely on the basis of reasons recorded by the AO and the material and information referred to by him in the reasons for initiating such action; the formation of the belief of the

The PSC is an independent accounting regime which includes tax treatment of costs, expenses, incomes, profits etc., it is because of the specific provision in the PSC for currency translation that loss/profit would accrue to an operator-company; ofte

the provision impugned is validly enacted and not hit by legislative incompetence of Central Legislature.

the assessee is entitled to deduction of roll over charges under section 36(1)(iii) of the I.T. Act, 1961.