Subscription   Feedback   New User   Login      
Tax Management India .com
TMI - Tax Management India. Com
Articles Highlights TMI Notes SMS News Newsletters Calendar Imp. Links Database Experts Contact us More....
Extracts
Home List
← Previous Next →

ITO -20 (3) (1) , Parel, Mumbai Versus Unno Source Corporation

2015 (12) TMI 1547 - ITAT MUMBAI

Exemption u/s. 10A - Held that:- CIT(A) correctly allowed the claim of the assessee observing that the assessee had satisfied the conditions for eligibility to claim exemption under section 10A of the Act. Also observed that the assessee’s claim has also been allowed for the two assessment years following its inception. The assessee has duly proved by various evidences that the business was actually carried out by the assessee and that there were 88 employees employed by the assessee and they we .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

ORDER Sanjay Garg (Judicial Member) The present appeal has been preferred by the Revenue against the order dated 07.03.2013 of the Commissioner of Income Tax (Appeals) [hereinafter referred to as the CIT(A)] relevant to assessment year 2009-10. 2. The Revenue has taken the following grounds of appeal: "1. On the facts and in the circumstances of the case and in law, the Ld. CIT(A) has erred in directing to allow exemption u/s. 10A of I.T. Act, 1961 without appreciating that neither A.O. nor .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

appellant prays that the order of Ld.CIT(A) on the above ground be set aside and matter be restored to the Assessing Officer. 4. The appellant craves leave to amend or to alter, any ground or add a new ground, which may be necessary." M/s Unno Source Corporation USA which was owned by Mr. Pranav Gundaria, his wife and 3. The brief facts of the case are that during the assessment proceedings, the Assessing Officer (hereinafter referred to as the AO) observed that the total expenses of the as .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

not possible to generate a turnover of ₹ 7.04 crores based on the incurring of such expenses. The AO also noted that as per transfer pricing report, the number of employees of the assessee concern was 80 but the salary register showed only 52 and observed that the assessee had not been able to prove the technical competence of any of the workers who provided the IT enabled services for civil engineering. The AO also took exception to the expenses incurred by the assessee towards foreign tr .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

l before the Ld. CIT(A). The assessee made a detailed submission in support of its claim and also furnished the additional evidences as mentioned in para 4.2 of the impugned order. The Ld. CIT(A) forwarded the said evidences to the AO for verification and comments. The AO thereafter conducted the investigation in respect of the evidences submitted by the assessee and came to the following conclusion: The firm has produced voluminous data regarding drawings in paper form and softcopy in form of 9 .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

 

 

 

 

 

what is new what is new
  ↓     bird's eye view     ↓  


|| Home || Acts and Rules || Notifications || Circulars || Schedules || Tariff || Forms || Case Laws || Manuals ||

|| About us || Contact us || Disclaimer || Terms of Use || Privacy Policy || TMI Database || Members || Site Map ||

© Taxmanagementindia.com [A unit of MS Knowledge Processing Pvt. Ltd.] All rights reserved.

Go to Mobile Version