Judgements by CS Bijoy

The relevant material facts are like this. The assessee before us, Dongfang Electric Corporation (DEC, in short) is a non-resident company - incorporated under the laws of, and fiscally domiciled in, the People’s Republic of China. The assessee had f

It is, thus, evident that DTAA recognizes the fact that the amendments made in the IT Act are not affected in so far or they are not in conflict with the specific provisions of the DTAA. Therefore we are of the view that the amendment made in sect

Facts, in brief, as per the relevant orders are that return declaring income of `.39,90,410/- was filed by the assessee on 18th July, 2006. Subsequently on 26th April, 2007, a search u/s 132 of the Income Tax Act 1961, (hereinafter referred to as the

Adverting first to ground no.1 in the appeal , facts, in brief, as per relevant orders are that e-return declaring income of ``28,24,41,510/- filed on 29.09.2008 by the assessee, a foreign company having permanent establishment in India, was selected

Briefly stated facts are that the AO has computed the interest u/s. 244A of the Act on the refundable amount without considering the interest incomes credited earlier in the tax computation statement as per the appeal effect order dated 21.06.2010. I

It was the submission by the ld. AR that the show cause notice issued u/s 263 of the IT Act on 23.01.2012 had not mentioned which order was erroneous nor had he mentioned the error in the assessment order. It was the submission that the show cause no

Facts, in brief, as per relevant orders are that e-return declaring income of ``32,780/- filed on 21.11.2006 by the assessee, engaged in the business of manufacturing and trading in home furnishing, after being processed u/s 143(1) of the Income-tax

The Income Tax authorities made re-assessments on 28.12.2007. The order was carried in Appeal. The Appellant had objected to the assumption of jurisdiction under Section-147 of the Act by the A.O. and also objected to the addition of certain amounts

By way of this appeal, the Assessing Officer has challenged correctness of Commissioner of Income Tax (Appeals)’s order dated 04.11.2011 in the matter of order u/s. 154 r.w.s. 143(3) of the Income Tax Act, 1961, for the assessment year 2005-06. The a

Having regard to Rule 19(2) of ITAT Rules, 1963 and following various decision of the Tribunal including in the case of C.I.T. vs. Multiplan India (P) Ltd., reported in 38 ITD 320 (Del.) and the judgement of Hon’ble Madhya Pradesh High Court in the c