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Showing 1 to 15 of 70388 Records

    2015 (3) TMI 1052 - ITAT AHMEDABAD

    The Income-tax Officer(Intl. Taxn.) Vadodara Versus M/s Denial Measurement

    Non deduction of tds on technical work and related to engineering - submission of the Assessee that the Services provided by the non- resident were not in the nature of “making available” hence Article 12 of India U.S.A. treaty were not applicable - ......

    2015 (3) TMI 1031 - DELHI HIGH COURT

    Commissioner of Income Tax-I Versus M/s Cotton Naturals (i) pvt. Ltd.

    Determination of arms' length rate of interest - ITAT holding that the interest @ 4% p.a. charged by the respondent assessee from its subsidiary i.e. the Associated Enterprise was arm's length rate of interest and the adjustment made in the A ......

    2015 (3) TMI 1030 - DELHI HIGH COURT

    Krown Agro Foods Pvt. Limited Versus Assistant Commissioner of Income-Tax Circle 5 (1) New Delhi

    Reopening of assessment - notice under Section 148 challenged - Held that:- The reason to believe recorded by the Assessing officer is not based on any material that had come to the knowledge of the Assessing Officer. There is a mere suspicion in the ......

    2015 (3) TMI 1029 - KARNATAKA HIGH COURT

    Commissioner of Income Tax And Others Versus M/s. Ankita Electronics Pvt Ltd.

    Penalty imposed under Section 271(1)(c) - Tribunal dismissed the appeal of the Revenue and the penalty imposed under Section 271(1)(c) has been disallowed - Held that:- Additions in respect of which penalty under Section 271(1)(c) of the Act was levi ......

    2015 (3) TMI 1028 - BOMBAY HIGH COURT

    Commissioner of Income Tax Versus M/s. Johnson And Johnson Ltd.

    Validly of reassessment proceedings - addition on account of sales made to Johnson & Johnson Exports Limited - Held that:- Tribunal noted that the law is that the reasons ought to be supplied on demand by the assessee. The assessee, therefore, had no ......

    2015 (3) TMI 1027 - RAJASTHAN HIGH COURT

    Commissioner of Income Tax-I Versus M/s. Gem Plaza

    Deduction u/s 80HHC on counter sales - whether ITAT as well as the CIT(A) was justified in allowing the deduction u/s 80 HHC when there is no finding to the effect that the goods were cleared at any of the custom station? - Held that:- Apex Court in ......

    2015 (3) TMI 1026 - BOMBAY HIGH COURT

    The Commissioner of Income Tax-II, Thane Versus Thane Bharat Sahakari Bank Ltd.

    Disallowances on the loss of shifting classified securities - Held that:- Tribunal in dismissing the revenue's appeal and upholding the order of the Commissioner found that similar exercise was undertaken by another assessee Latur Urban Coop. Ban ......

    2015 (3) TMI 1025 - ITAT MUMBAI

    M/s Livingstones Versus Deputy commissioner of Income Tax, 16(3), Mumbai

    Transfer pricing adjustment - assessee has challenged the addition on account of transfer pricing adjustment in respect of sale made to the associated enterprise by applying comparable uncontrolled price method instead of transactional net margin met ......

    2015 (3) TMI 1024 - ITAT BANGALORE

    NTT DATA FA Insurance Systems (India) Private Limited (Formerly known as First Apex Software Technology Private Limited) Versus Deputy Commissioner of Income Tax

    Transfer pricing adjustment - Computation of Arms Length Price - selection of comparable - Held that:-Flextronics Software Systems Ltd. 595.12 crores and Infosys Technologies Ltd. 9028.00 crores whose turnover is above ₹ 200 Crores should be ex ......

    2015 (3) TMI 1023 - ITAT JAIPUR

    M/s. Tata Teleservices Ltd. And Others Versus Income Tax Officer, TDS-1, Jaipur

    Liability for TDS u/s 194H - discount on sale of recharge vouchers (RCVs) and the starter kits by the appellant to its channel partners (distributors/ dealers) - Held that:- The relationship between assessee and its distributors qua the sale of impug ......

    2015 (3) TMI 1022 - ITAT DELHI

    Macquarie Global Services Pvt. Ltd. Versus DCIT, Circle-6(1), New Delhi.

    Transfer pricing adjustment - selection of comparable - Held that:- Cosmic Global Ltd. company outsourced its activities and the outsourcing expenses constitute 57% of the total expenses. The entire outsourcing is confined to Translation charges pai ......

    2015 (3) TMI 1021 - ITAT DELHI

    M/s. Minda Capital Ltd. Versus DCIT

    Disallowance u/s 14A - A.R. submitted that the A.O. has made disallowance u/s 14A as per the provisions of Rule 8D without recording satisfaction which is mandatory in law and therefore, the disallowance is not sustainable - Held that:- In the presen ......

    2015 (3) TMI 1020 - ITAT DELHI

    ITO & Anr Versus Mehra Jewel Palace Pvt. Ltd. & Anr

    Addition on undisclosed profit - Held that:- A.O. has based his findings on the basis of surmises and conjectures and that too without commenting upon the explanations of assessee. Moreover, in the present year, we find that assessee has not earned a ......

    2015 (3) TMI 1019 - ITAT JAIPUR

    M/s. Pushp Enterprises Versus Asstt. Commissioner of Income Tax, Circle-4, Jaipur

    Concealed sales of scrap - assessee could not give evidence regarding non return of the scrap by the vendors/subvendors doing job work for and it is most unlikely that assessee will allow vendors/sub-vendors to keep scrap with them, on which it is pa ......

    2015 (3) TMI 1018 - ITAT MUMBAI

    Asst. CIT, Central Circle-13, Mumbai Versus Prakash Steelage Ltd.

    Levy of penalty u/s.271AA - CIT(A) deleted the penalty levy - Held that:- The ingredients of section 271AAA, for which reference may be made to subsections (1) and (2) thereof, and which provision only is applicable for the current year - the year of ......

   
 
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