We have carefully considered the submissions of the rival parties and perused the material available on record. The undisputed facts of the case in brief are that the assessee company is a fully owned subsidiary of Yahoo. Inc. USA which is engaged in
Your appellant submits that your appellant has not received any interest from the Partnership firm and as such the learned CIT(A) ought to have considered this and ought not to have confirmed the addition of Rs.6,56,049/- made by the learned A.O. on
Question raised in the case is. Whether on the facts and circumstances of the case the Ld. Commissioner of Income Tax (A) was justified in rejecting the appeal of the assessee and confirming the order of the ITO, Ward 32(3) and confirming the additio
The ground raised in the appeal is that on the facts of the case and in law the Ld. Commissioner of Income Tax (A) erred in confirming that the Derivative Loss of ` 1,15,880/- on dealing in future and option derivatives of shares in Recognized Stock
The assessee companies in the present cases along with some other entities were promoters of a company namely M/s. Dawn Mills Co. Ltd. and were holding 52.60 percent shares of the said company. They agreed to transfer their shares and controlling int
Although all these appeals have been filed by the revenue however the ld. AR submitted that under Rule 27 of Income Tax (Appellate Tribunal) Rules, 1963, assessee wants to support order on the ground of reopening decided against the assessee by the C
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
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