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2015 (7) TMI 147 - ITAT DELHI

Kohinoor Foods Ltd. Versus Assistant Commissioner of Income-tax

Rejection of the books of account of the assessee for the reason that assessee is not maintaining qualitative stock tally - Held that - It is not disputed that the assessee s yield commensurate to the industrial GP disclosed by the assessee is compar.....

2015 (7) TMI 145 - ITAT RAJKOT

Chorwadi Mataji Mandir Trust, Versus The Commissioner of Income-tax

Registration sought by the assessee-trust u/s 12AA refused - Held that - Going through the orders of the authorities below as well as the Order of the Co-ordinate Bench in the case of Shree Chargam Dasha Porwad Mahamandal v. DIT (Exemption) 2015 (7) .....

2015 (7) TMI 144 - ITAT AHMEDABAD

Shri Ajaykumar J. Patel Versus Dy. Commissioner of Income tax

Validity of reassessment proceedings u/s. 147/148 - assessment of deemed sales consideration u/s. 50C - Held that - The case was reopened u/s. 148 after recording the reasons within 4 years. The assessee had not disclosed long term capital gain in th.....

2015 (7) TMI 143 - ITAT AHEMADABAD

Shree Vanchhara Tirthadhipati Chintamani Parswaprwabhu Trust Vs. The ADIT

Registration under section 12AA denied - DIT(E) refused the registration to the trust for the reason that there was no clause with respect to transferring the assets - Held that - As decided case of Shri Chargam Dasha Porwad Mahamandal 2015 (7) TMI 1.....


C.I.T Central-II, Kolkata Versus Balarampur Chini Mills Ltd.

Penalty under Section 271(1(c) - additional income due to the search operation u/s 132 - assessee disclosed the additional income only after he was confronted by the D.I (Inv), New Delhi with certain evidence - Held that - In the case, before us the .....


Emaar Alloys Pvt. Ltd. Versus Director General of Income Tax (Investigations) And Others

Legality of search and seizure operations under Section 132 - Held that - We see no reason to entertain this writ petition mainly for the following facts and reasons (i) This petitioner has close connection with Ex. Chief Minister of the State. (ii) .....

2015 (7) TMI 125 - ITAT DELHI

M/s Fiserv India Pvt Ltd Versus DCIT, Circle-11 (1) , New Delhi

Transfer pricing adjustment - selection of comparable - Held that - For M/s E-Infochips Bangalore Ltd. profit margin of such entity in the immediately preceding year(s) may also be taken into consideration and the FAR analysis in such cases may be re.....

2015 (7) TMI 124 - ITAT DELHI

M/s Fiserv India Pvt Ltd Versus ITO, Ward-13 (4) , New Delhi

Transfer pricing adjustmeent - arm s length price of the international transactions representing software development services provided to the associated enterprises (AE) is determined by applying transactional net margin method (TNMM) - selection of.....

2015 (7) TMI 123 - ITAT PUNE

Dy. CIT, Central Circle, Aurangabad Versus Shri Naresh B. Jindal,

Penalty levied u/s.271(1)(c) - undisclosed income in the hands of director - CIT(A) deleted penalty levy - Held that - CIT(A) deleted the penalty holding that the profit offered to tax by the directors of the different companies including the assesse.....

2015 (7) TMI 122 - ITAT PUNE

Shri Shivgaya Ramkumar Gupta Versus DCIT, Circle-9, Pune

Disallowance u/s 40(a)(ia) - Non deduction of TDS on the labour charges paid - whether payment has been made for centring, tiling and fabrication work amounts to payment to contractor or sub-contractor so as to invoke provisions of section 194C (2) f.....

2015 (7) TMI 121 - ITAT PUNE

Dy. CIT, Central Circle, Aurangabad Versus Shri Arun S. Agrawal and Others

Penalty levied u/s.271(1)(c) - undisclosed income in the hands of director - CIT(A) deleted penalty levy - Held that - CIT(A) deleted the penalty holding that the profit offered to tax by the directors of the different companies including the assesse.....

2015 (7) TMI 120 - ITAT PUNE

M/s. Modi Builders Versus JCIT, Range-5, Pune

Disallowance of expenditure paid to Pune Municipal Corporation(PMC) for regularizing the excess area constructed for a building called MODI MALL by invoking the Explanation to sec 37(1) - Held that - Compounding fee paid by the assessee to the Munici.....

2015 (7) TMI 119 - ITAT CHENNAI

Joseph Prince and others Versus The Assistant Commissioner of Income Tax, Central Circle I (5) Chennai

Legality of assessment u/s.153A - Held that - There are certain additions made by the Assessing Officer on the basis of information which was available with the assessing authorities in the form of earlier returns of income and financial statement at.....

2015 (7) TMI 118 - ITAT AHMEDABAD

Arvind Ltd. (formerly known as the arvind Mills Ltd.) Versus DCIT, Cir-1, Ahmedabad, DCIT, Cir-1, Ahmedabad. Versus Arvind Ltd. (formerly known as the arvind Mills Ltd.)

Disallowance u/s.14A - Held that - There is no dispute in assessee s appeal that the authorities below have invoked Rule 8D(2)(ii) and (iii) of the Income Tax Rules in computing the impugned section 14A disallowance. The assessment year in question i.....

2015 (7) TMI 117 - ITAT HYDERABAD

M/s. SPR Publications P. Ltd. and others Versus ACIT, Circle 3 (2) Hyderabad and others

Disallowance made u/s.40(a)(ia) - TDS remittance made before the due date of filing of return of income was not in conformity with the provisions of section 40(a)(ia) - Held that - The department has not disputed the fact that the expenditure claimed.....

2015 (7) TMI 116 - ITAT MUMBAI

M/s Perstorp Chemicals India Pvt. Ltd Versus Income Tax Officer and others

Transfer pricing adjustment - the TPO determined the ALP of Royalty and Technical knowhow fee as NIL as the assessee did not furnish the details that were called for - Held that - The decision of the TPO to determine the ALP as NIL is also not in acc.....

2015 (7) TMI 115 - ITAT DELHI


Addition on account of interest income - revenue v/s capital receipt - diversion of interest at source - Held that - The interest earned on FDR before commencement of project was to be treated as capital receipt to be adjusted preoperative expenses, .....

2015 (7) TMI 114 - ITAT JAIPUR

Smt. Kavita Rangwani and others Versus The I.T.O. Ward-6 (1) , Jaipur and others

Unexplained deposits in bank account - appellant is a housewife - Held that - Ld. Counsel for the assessee contends that ld. CIT(A) has given clear findings of facts and held that the opening cash of 2.75 lacs and withdrawal of ₹ 1 lac contribu.....

2015 (7) TMI 113 - ITAT MUMBAI

M/s. Kreuz Subsea Pte. Ltd Versus The Deputy Director of Income Tax, Mumbai

Service PE in India - India Singapore DTAA - whether in the case of the assessee, the Service PE can be said to be established/constituted within the scope of Article 5(3) or Article 5(6)? - Held that - The threshold period under this para is 90 days.....

2015 (7) TMI 112 - ITAT RAJKOT

Backbone Construction P Ltd And Others Versus Deputy Commissioner of Income Tax, Central Circle-2, Rajkot And Others

Estimation of net income at the rate of 16 - Held that - The estimate of net income from the contract work at the rate of 16 of the turnover was without any basis. We find that as per the provisions of section 44AD of the Income Tax Act, net profit f.....

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