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Income Tax - Case Laws
Showing 61 to 80 of 643 Records
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2015 (4) TMI 1259
Claiming of deduction u/s. 80IB(3) - Status of SSI ceased in 9th year - When once the eligible business of an assessee is given the benefit of deduction u/s 80IB on the assessee satisfying the conditions mentioned in Sub-sec.(2) of Sec.80IB, can the assessee be denied the benefit of the said deduction on the ground that during the said 10 consecutive years, it ceases to be a small scale industry – Held that:- The issue is now covered by the decision of the Tribunal in the own case of the assessee for earlier assessment year 2009-10 [2014 (8) TMI 596 - KARNATAKA HIGH COURT] in the entire provision, there is no indication that these conditions had to be fulfilled by the assessee all the 10 years - When once the benefit of 10 years, commencing from the initial year, is granted, if the undertaking satisfy all these conditions initially, the undertaking is entitled to the benefit of 10 consecutive years
If the object of the Legislature providing for the incentives is kept in mind and when a period of 10 years is prescribed, that is the period, probably, which is required for any industry to stabilize itself - Merely because an industry stabilizes early, makes profits, makes future investment in the said business, and it goes out of the definition of the small scale industry, the benefit u/s 80IB cannot be denied - If such a literal interpretation is placed on the said provion, it would run counter to the very object of granting incentives - the benefit of deduction is given to an assessee who has availed the opportunity given to him under law and has grown in his business - if a small scale industry, in the course of 10 years, stabilizes early, makes further investments in the business and it results in it’s going outside the purview of the definition of a small scale industry, that should not come in the way of its claiming benefit u/s 80IB for 10 consecutive years, from the initial assessment year – Decided in favour of Assessee.
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2015 (4) TMI 1257
Disallowance of bad debts written off - Held that:- Now it is quite settled law that, if the bad debts has been written off in the books of account, then it is not necessary for the assessee to establish that debt has become irrecoverable. It is the decision of the assessee to write off the bad debt as irrecoverable in the accounts of the assessee. This proposition has been quite settled in the case of TRF Ltd. Vs. CIT [2010 (2) TMI 211 - SUPREME COURT] and catena of other decisions. However, from the perusal of the order of the appellate order, it is seen that, Ld. CIT(A) has made on observations that assessee has not written off the bad debts in the account of M/s. Kiraj Consultants Pvt. Ltd. and in its books of account.
Learned counsel has filed a copy of general ledger account and also the parties account of M/s. Kiraj Consultants Pvt. Ltd., wherein it has been clearly shown that amount of ₹ 2,61,09,809/- has been transferred to bad debts. Even in the P&L Account, in schedule 12 the bad debts written off [net of provisions] have been shown. Thus, this matter needs verification from the end of the AO to see, whether the bad debts has in fact been written off in accounts of the assessee or not - Appeal filed by the Assessee is partly allowed for statistical purposes.
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2015 (4) TMI 1256
Depreciation @60% on all equipments falling under the head ‘Computers’ including ‘Bizebra Weighing Scale’ - whether the same is weighing scale and not included in the list of hardwares defined as ‘computer’? - Held that:- As observed that a computer, in common sense and as popularly understood, refers to any electronic or high speed data processing device which performs logical, arithmetic and memory functions on data whereas weighing scale fairly do not fall within the ambit of computer. These are only peripherals which draw support from computer for its functions. Most of the computers are used in coordinating with other machineries for weighing articles, generating cash memo, etc. Therefore the basic function of the weighing scale falls in the category of plant and machinery and depreciation @15% is allowed.
CIT(A) merely reproduced the contentions of the assessee as well as the decision of the Special Bench of ITAT, Mumbai in the case of Datacraft India Ltd. [2010 (7) TMI 642 - ITAT, MUMBAI] and observed that weighing scale should be treated as computer hardware and accordingly allowed the claim of the assessee. It deserves to be noticed that the detailed functions of the weighing scale were not mentioned by the CIT(A). It is not known as to what are the substantial functions of the weighing scale and whether they can independently be operated or not, in order to consider as to whether they are part of computer hardware or not.
We set aside the order of the CIT(A) and direct the AO to reconsider the matter by taking into consideration the technical details of the weighing scale and analyse the same in order to appreciate as to whether the functions of the weighing scale fall within the meaning of computer hardware as specified by the ITAT Special Bench in the case of Datacraft India Ltd. With these observations the appeal filed by the Revenue is treated as allowed for statistical purposes.
Legal/professional and sales promotion expenses - to be treated as capital expenditure or revenue in nature - Held that:- Similar agreement was entered into with M/s. A.T. Kerney Ltd. and the payment was made for the launch of the retail business and therefore it has to be treated as pre-operative expenditure and it gives the assessee an enduring benefit in which event the expenditure has to be treated as capital in nature. Though the assessee filed a paper book, as per Rule 18(6) of the Appellate Tribunal Rules, only those papers which were referred to and relied upon by the parties during the course of arguments shall alone be treated as part of the record of the Tribunal whereas in the instant case none appeared before us and no material, whatsoever, was brought to our notice and therefore the paper book cannot be taken into consideration. Thus, the assessee has not brought any material to controvert the findings of the learned D.R. Even otherwise the paper book consists of copies of the agreements with three parties and the same were already considered by the CIT(A). Having regard to the circumstances of the case we do not find any infirmity in the order passed by the CIT(A) and accordingly we dismiss ground No. 1 of the assessee.
Treating of foreign travelling expenditure as capital in nature - Held that:- CIT(A) considered the issue in para 5.3 of his order wherein he observed that foreign travel was for procuring capital goods and hence the AO was justified in disallowing an amount proportionate to the amount of capital goods imported. Here also no material was brought to our notice to controvert the findings of the CIT(A). We, therefore, do not find any justification to interfere with the order passed by the learned CIT(A) on this aspect. Therefore ground No. 2 of the assessee is rejected.
Disallowance computed under section 14A read with Rule 8D - Held that:- Share application money is also an investment and it has to be considered in the investment while working out the average of investment and accordingly worked out the amount disallowable under section 14A read with Rule 8D. Here also no material, whatsoever, was placed to controvert the findings of the learned CIT(A). We, therefore, affirm the order of the learned CIT(A) on this aspect also and dismiss ground No. 3 of the assessee.
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2015 (4) TMI 1255
Grant of deduction u/s 54F - assessee could not be constructed by the builder for a sufficient long time and the same could not be categorised as residential house - Held that:- The assessee had booked a residential flat on 15.01.1981. The builder failed to complete the construction and the dispute travelled to the Hon’ble Bombay High Court.
The Hon’ble Bombay High Court had appointed a committee/receiver with a direction to complete the construction. The construction of the building was not complete up to Feb 2011 as has been gathered by the CIT(A) from the letter dated 17.02.2011 issued by the said committee of court receiver. The assessee, however, in the year 2005 had sold the unconstructed/under construction unit resulting in taxable long term capital gains.
CIT(A) has categorically held, after appreciation of the factual matrix of the case, that the property transferred by the assessee could not be termed to be a residential house. The findings of the CIT(A) have been reproduced above. The provisions of section 54F are beneficial provisions enacted for the purpose of promoting the construction/purchase of residential houses. The property in question sold by the assessee could not be constructed by the builder for a sufficient long time and the same could not be categorised as residential house and therefore the claim of the assessee has rightly been allowed by the Ld. CIT(A) under section 54F. No infirmity on the order of the CIT(A) in this respect. - Decided in favour of assessee.
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2015 (4) TMI 1254
Application of Blanket Rate of Tax - computation of tax based on different rates in the assessment orders - computation of tax on royalty income - India-USA DTAA Treaty - Held that:- Hon'ble Apex Court in the case of CIT v. Vegetable Products Ltd. (1973 (1) TMI 1 - SUPREME COURT) has held that where a provision in the taxing statute is capable of two reasonable interpretations, the view favourable to the assessee is to be preferred. We are of the considered opinion that the computation of tax by the assessee in respect of royalty income is to be accepted. In this view of the matter, the grounds of appeal raised at S. Nos.2,3,4 and 5 are accordingly allowed.'
Following the directions of this co-ordinate bench of this Tribunal in the assessee's own case for Assessment Year 2007-08 in IBM World Trade Corpn's case (2012 (5) TMI 58 - ITAT BANGALORE ), on identical facts and issues, we hold and direct that the computation of tax submitted by the assessee in respect of royalty income is to be accepted. In this view of the matter, the grounds of appeal raised at S.Nos.2 to 8 are accordingly allowed.
Levy of interest u/s.234B - Held that:- Tribunal in the assessee's own case for Assessment Year 2007-08, with which we do not find any reason to differ as it was on similar facts and issues, we hold that the assessee is not liable to be charged interest under Section 234B of the Act.
Penalty u/s 271(1)(c) - Held that:- We find that since no penalty thereunder has been levied on the assessee in the impugned order of assessment for Assessment Year 2008-09, no cause of grievance arises therefrom in respect of the assessee, requiring our adjudication. In this factual matrix, this ground raised by the assessee is not maintainable
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2015 (4) TMI 1253
Addition u/s 14A - Held that:- Respectfully following the order of the ITAT in the case of the assessee itself for the assessment year 2006-07 (supra), on identical issue, we remand the matter to the file of the Assessing Officer to decide the issue afresh after affording opportunity of being heard to the assessee in view of the order of the ITAT passed in the assessment year 2006-07. These grounds are accordingly allowed for statistical purposes.
TPA - interest rate charged to the subsidiaries - contentions of the assessee remained that the interest rates were accepted at arm's length in the earlier years since the interest rates cannot be changed year after year, therefore, the same should be considered at arm's length this year also - Held that:- Considering above submissions, we find that it is an undisputed fact that in the earlier assessment years 2005-06 and 2006-07, the interest rates have been accepted at arm's length. in the case of Bhansali & Co [2014 (12) TMI 1149 - ITAT MUMBAI] held DRP erred in considering the loan as loan from India. The fact of the matter is that it was a foreign currency loan which was given abroad. Therefore the most appropriate method is taking the LIBOR as correct benchmark - the benchmarking done by the assessee is correct and the AO is directed to delete the addition.
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2015 (4) TMI 1251
Appeal admitted on:-
(1) Whether on the facts and circumstances of the case and in law, the ITAT was justified in holding that interest received by the assessee, out of funds placed with its HO and other overseas branches, is not taxable in India?
(2) Whether on the facts and circumstances of the case and in law, the ITAT was justified in holding that interest payable by the Indian branch / permanent establishment of the foreign bank to its head office and other overseas branches, is deductible in computing the total income ?
(3) Whether on the facts and circumstances of the case and in law, the ITAT was justified in holding that provisions of section 40(a)(i) are not applicable on interest payable by the Indian branch / permanent establishment of the foreign bank to its head office and other overseas branches, as it does not give rise to any income although as per the deeming provisions of article 7 of the concerned DTAA the income of the branch is to be computed as a separate and a distinct identity from the main entity and for the computation of income the provisions of domestic law are applicable ?
Addition on account of deferred guarantee commission - ITAT not deciding the case on merits and setting aside the matter on the issue to the assessing officer - Held that:- The matter has been sent back to the authority, lower to the Tribunal for a decision on merits. Merely because a order passed in the case of Bank of Bahrain and Kuwait [2010 (8) TMI 578 - ITAT, MUMBAI] has been brought to the notice of the parties and the assessing officer, does not necessarily mean that the issue will not be decided by him in accordance with law. We do not see any basis for entertaining this question.
Addition u/s 14A - Held that:- ITAT was justified in holding that no interest section 14A for earning of interest income on tax free bonds as the assessee has sufficient interest free funds available.
Setting aside the matter to the assessing officer on the issue of applicability of provisions of section 115JA to foreign companies - No substantial question of law.
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2015 (4) TMI 1250
TDS u/s 194A - cooperative society engaged itself in the business of banking liability to deduct tax on the income/interest paid to depositors/ members - Held that:- Section 194A(3)(v) of the Act says that when the interest is credited or paid by a co-operative society to a member or any other co-operative society, tax need not be deducted. Section 194A(3)(v) of the Act does not refer to a cooperative society carrying on the business of banking. It simply says that “income paid or credited by a co-operative society”. Therefore, the provisions of Section 194A(3)(v) may not be applicable to a co-operative society which carries on the banking business, since the co-operative society which carries on banking business is differently treated by the Parliament in Section 194A(3)(i)(b) of the Act.
Assessee's being co-operative societies engaged in carrying on the business of banking, are liable to deduct tax in respect of interest on time deposit to the members when it exceeds ₹ 10,000/-. However, in view of Section 194A (3)(viia)(b) in respect of other deposits, such as Savings Bank deposit, Recurring Deposit, other than time deposit, the assessee are not liable to deduct tax. Since the assessee's are co-operative societies engaged in banking business, they cannot have any transaction with non-members. Therefore, the question of payment of any interest to non-members does not arise for consideration.
In the case before us, no details are available with regard to nature of deposit on which interest was paid. It is not clear whether the interest was paid on the time deposit or in respect of other deposits, such as Savings Bank deposit, Recurring Deposit, etc. Therefore, the matter needs to be verified. Accordingly, orders of the lower authorities are set aside and the issue of deduction of tax is remitted back to the file of the Assessing Officer for a limited purpose of verifying the nature of deposits on which the interest was paid. It is made clear that the assessees are liable to deduct tax on the interest paid to their members on the time deposit. However, the assessees are not liable to deduct tax on the interest paid on Savings Bank account and Recurring deposit account. - Decided partly in favour of assessee.
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2015 (4) TMI 1249
Nature of income - treatment to the income from Sale of Shares as Business income OR Short Term Capital Gain - intention behind the purchases - Held that:- When the assessee itself is shifting his stand and offering the profit arising from sale and purchase of shares as business income and subsequently as a short term capital gain, then the rule of consistency will also be applicable on the assessee and not on the AO alone.
In view of the fact that all the transactions of sale and purchase are carried out in such a fashion that it cannot be regarded that the assessee purchased the shares with the intention to retain and hold the same for a longer period and for appreciation of value but the sale of the shares within a short period of time and within a period of one week in the most of the cases clearly manifest the intention of the assessee that the transactions were not undertaken by the assessee with a view to keep the same as investment. Accordingly, we do not find any error or illegality in the orders of the authorities below. - decided against assessee.
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2015 (4) TMI 1248
Disallowance u/s 14A with reference to investment in partnership firm - Held that:- Assessee has bifurcated the expenses relating to various branches which cannot be considered at all for the earning of the exempt income, which has been worked out at 1,16,01,123. Out of the balance amount, expenditure like godown rent and warehousing charges, other trading expenses insurance, foreign following travelling, business promotion etc. aggregating to ₹ 1.15 crores cannot be considered as expenditure incurred for the purpose of earning exempt income.
The balance expenditure comes to 2.59 crores and if salary cost of approximately 2.12 crores is added then the same comes to ₹ 4.71 crores. If from the total expenditure of ₹ 4.71 crores, the assessee itself has disallowed ₹ 1,65,43,645/-, then definitely it can be held to be reasonable attribution for the purpose of disallowance u/s 14A. Thus, the disallowance made by the AO over and above the disallowance and confirmed by the Ld. CIT(A) is deleted and accordingly, the order of the Ld. CIT(A) on this score is reversed. - Decided in favour of assessee.
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2015 (4) TMI 1247
Disallowance of deduction claimed u/s 35(2AB) - Assessee is involved into In-House Research & Development activities, which are undertaken at Pune center - Held that:- It is not the case of the revenue authorities that the assessee was not doing scientific research. It is a fact that the assessee was conducting research in its field earlier, is evident from the letter received from Mr. R.R. Abhyankar (Scientist G) reads as renewal, therefore, it means that the relevant approval had been received and when we read the preceding letter also, we find that it talks about renewal from 01.04.2010. In fact vide letter dated 09.01.2008 the nodal officer from the department of Scientific & Industrial Research had accorded the recognition upto 31.03.2010. However all these facts require verification. Hence, this issue is set aside to the file of the AO. Appeal as filed by the assessee is treated as allowed for statistical purposes.
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2015 (4) TMI 1246
Assessment of income on account of purchase and sale of shares - income from business or income from other sources - assessee had failed to establish the genuineness of the transactions with documentary evidence and also Bombay Stock Exchange had confirmed that no transaction as mentioned in the contract notes had been executed on the Stock Exchange - Held that:- The perusal of details annexed in annexure A to the assessment order also reflects the transaction to have happened in over 1 – 3 days and in the absence of the assessee having established that it had taken delivery of the said shares, the gain arising on such transfer cannot be assessed as income from capital gains or income from business. We find merit in the order of Assessing Officer that since the assessee had failed to explain with documentary evidence, the introduction of unaccounted / undisclosed income to the tune of ₹ 65,51,352/- in the guise of short term capital gains on sale of shares, the same is to be assessed in the hands of the assessee as income from other sources. In the absence of assessee having furnished the details of said shares and establishing the factum of transfer of shares, we reverse the order of CIT(A) and uphold the order of Assessing Officer. - Decided against assessee.
Addition of revenue expenditure - acquisition of capital asset - Held that:- The assessee before us has failed to establish its case and where the intention of the assessee was to acquire a capital asset, the payment of advance money of ₹ 25 lakhs being paid on capital account and its forfeiture would result into capital loss and the same cannot be allowed as revenue expenditure.- Decided against assessee.
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2015 (4) TMI 1245
Penalty u/s. 271AAA - assessee failed to substantiate the manner in which undisclosed income has been derived - question regarding manner of earning income - Held that:- Referring to observation in case of CIT v. Mahendra C. Shah [2008 (2) TMI 32 - GUJARAT HIGH COURT] it becomes clear that if no question is asked during the statement recorded u/s.132(4) then the assessee cannot be expected to further substantiate the manner of earning of income. In the present case also Revenue never asked any question regarding manner of earning the income therefore following above order we decide this issue against the revenue. Accordingly we set aside the order of Ld. CIT(A) and delete the penalty. - Decided in favour of assessee.
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2015 (4) TMI 1244
Allowability of expenditure on foreign traveling in the units other than the STP-I unit - allowable busniss expenses - Held that:- In the absence of any discussion on facts in the assessment orders for the years under consideration the issue necessarily has to be restored to the AO. Accordingly the appeal of the assessee and the Revenue in the respective assessment years are being restored back to the AO with the direction to decide the issue raised therein qua the addition made by way of a disallowance discussing the relevant facts in the respective years. Needless to say that before passing the order the assessee shall be afforded a reasonable opportunity of being heard. Appeal allowed for statistical purposes.
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2015 (4) TMI 1243
Proportionate deduction u/s 80IB(1) - existence of any provision for pro rata deduction in the statute - some of the flats violated the condition of not exceeding area of 1000 sq. `ft. and thus vitiating the whole project - Held that:- The Registrar (Judicial)/Registrar, High Court, Original Side, Bombay to ensure that the original record in relation to this Appeal is summoned from the Tribunal and offered for inspection of the parties. This paper book is treated sufficient for the purpose of admission of this Appeal. However, the Registry must further ensure preparation of complete paper book in accordance with the Rules. The Registry in the first instance must send intimation of admission of this Appeal enclosing therewith a copy of this order so as to enable the Tribunal to act accordingly.
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2015 (4) TMI 1242
Expenses incurred on temporary errection/accommodation is fully allowable expenditure - Held that:- Assessee has been maintaining proper books of account and in the light of the nature of activities undertaken by the assessee, we find force in the contentions of the assessee that at every site temporary constructions are made and a particular percentage of expenditure is debited to the account under the head “temporary site accommodation” and whatever materials were left out from the site, they are being reutilized further. No excess claim was raised by the assessee. Since no disallowance was ever made in earlier assessment years, we find no justification in the disallowance made in this very assessment year, as the Assessing Officer cannot blow hot and cold in the same breath by admitting the claim of the assessee in one assessment year and denying the same in the succeeding assessment year. Claim of the assessee is reasonable and is allowable.
Disallowance of expenses incurred on shuttering, centering, scaffolding, etc. - Held that:- The nature of complexity of the work, we are of the view that the assessee’s claim of expenses on shuttering, centering, scaffolding, etc. raised as per circulars issued by the Department is an allowable expenditure in the light of the order of the Tribunal in the assessee’s own case. It is also evident from the record that in earlier year no disallowance was made on this account. Therefore, following the rule of consistency, disallowance cannot be made in the impugned assessment year without any valid reason. No merit in the disallowance and we set aside the order of the ld. CIT(A) and delete the addition in this regard.
Disallowance of prior period expenses - Held that:- Similar arguments as raised before the ld. CIT(A), but could not place any documentary evidence to substantiate that the prior period expenses have been crystallized in the impugned assessment year. In the absence of any evidence, we find no merit in the contentions of the assessee. Accordingly, we confirm the order of the ld. CIT(A) who has rightly dealt with the issue.
Disallowance of deduction under section 80-IA - Held that:- In the light of the rival submissions, we find that the claim of deduction under section 80-IA of the Act was allowed in assessment years 2005-06 and 2007-08 by the Assessing Officer himself and in assessment year 2003-04 the claim was disallowed, but later on it was allowed by the ld. CIT(A) and the Revenue has not challenged the order of the ld. CIT(A) before the Tribunal. Therefore, it attained finality. Therefore, in the light of these facts, we find no infirmity in the order of the CIT(A) who has rightly allowed the claim of the assessee under section 80-IA
Disallowance of provision for “foreseen loss” - Held that:- Assessee has not placed any evidence on record to demonstrate the basis for making provision for “foreseen loss”. No doubt, foreseen loss may be possible in the business of the assessee as it is engaged in complicated construction work, but without any basis provision for foreseen loss cannot be created. Whenever loss is suffered, it can be debited to its profit and loss account and the Revenue may allow the same after making necessary verification. We hold that in the impugned assessment year provision for foreseen loss cannot be allowed, but the assessee will be allowed to debit the actual loss suffered by it in any of the assessment year and the same would be allowed by the Revenue after making necessary verification.
Disallowance of prior period expenses booked in this year - Held that:- We have confirmed the addition having noted that the assessee could not place any evidence to establish that the prior period liabilities have been crystalised in the impugned assessment year. Similar is the position in the instant case, as nothing is placed on record to establish that the liabilities for earlier years have been crystalised in the impugned assessment year. Accordingly, following the view taken in the foregoing paras, we confirm the addition.
Provisions of section 40(a)(ia) - Held that:- We are of the view that this issue requires a fresh adjudication by the lower authorities after necessary verification with regard to the nature of payment. Accordingly we set aside the order of the CIT(A) and restore the matter to the file of the Assessing Officer with a direction to adjudicate this issue in the light of evidence with regard to the nature of payment. Accordingly, this appeal of the assessee is disposed of.
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2015 (4) TMI 1239
Exemption u/s 10A - treatment to the new unit - Whether on facts and circumstances of the case, the Hon'ble ITAT has erred in holding that new unit is to be treated as a separate and independent unit for the purpose of computing deduction u/s 10A of the Act? - Revenue appeal admitted - tagged with another appeal.
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2015 (4) TMI 1237
Entitle to deduction u/s 80P(2)(d) against the gross interest income by applying the provisions of section 14-A read with rule 8D - Held that:- As decided in assessee's own case in assessment year 2010-11 we decide this issue principally against the assessee. However, the Assessing Officer should re-compute the disallowance after verifying the calculation of disallowance u/s 14A read with Rule 8D after verification of the figures submitted by the Assessee.
Not allowing deduction u/s 80P(2)(c) - Held that:- After considering the rival submissions we find that though some submissions have been made but no evidence was brought before us to show that activities of the society was not within the activities mentioned in section 80P(2)(a) & (b), therefore, we find nothing wrong with the order of Ld. CIT(A) and confirm the same.
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2015 (4) TMI 1236
Unexplained money - unexplained receipt of share application money - Held that:- AO gives a finding that the money was received from one company and in turn was invested in another company. There is no finding that money received was unexplained. Invoking the provisions of Section 68 / 69 require a finding by AO that the credit is un-explained. There is no such finding either in the assessment order or in the Remand Reports.
Just because another Government authority is investigating the fund flow, it cannot be conclude that the funds received by assesseecompany are un-explained. No reason to interfere with the order. However, this finding is only with reference to the provisions of the Act and should not come in the way of CBI investigating the various sources of funds and Revenue is free to take necessary action in case the funds are found to be un-explained. - Decided against revenue
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2015 (4) TMI 1235
Nature of income - sum received by the assessee from ICICI Bank - assessable under the head “income from house property” OR “income from other sources” - Held that:- Common ground between the parties that in A.Y. 2005-06 the issue came up before the Tribunal the issue was decided in favour of the assessee the fact that the agreement for letting out the premises to ICICI Bank Ltd. is for a period of 15 years, clinches the issue in favour of the assessee as they become the deemed owner under the provision of section 27(iiib) r.w.s. 269 UA (f)(i) of the Act and accordingly is entitled to deduction as provided u/s 24(a) of the Act - no mistake in the order of CIT(A) in holding that the assessee is the deemed owner of the premises u/s 27(iiib) of the Act and the order of the CIT(A) is confirmed and the grounds of appeal of the revenue are dismissed.
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