9911796707
TMI Blog2023 (7) TMI 1490X X X X Extracts X X X X X X X X Extracts X X X X ..... r of Income Tax, Commissioner of Income Tax, Additional Commissioner, Government of India, Ministry of Finance,Income Tax Department, National E Assessment Centre, Delhi, Joint Commissioner, Government of India, Ministry of Finance, Income Tax Department, National E Assessment Centre, Delhi, Joint Commissioner of Income Tax, Lok Nayak Bhawan, Dakbanglow Raod, Dy. Commissioner, Government of India, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he Assessing Officer in proceedings initiated under Section 147 read with Section 148 of the Income Tax Act, 1961. We have to immediately notice that the said contention cannot be urged in a petition under Article 226 and an appeal at this point is grossly barred by limitation, especially considering the fact that the order was dated 30.12.2017. The writ petition itself was filed delayed. 2. We h ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r 20 years and that it was renovated and beautified for use as a conference hall. The asset was found to be a building existing for more than an year, thus, limiting the claim of depreciation to 10% as against the returned claim of 50%. 4. Madras Auto Service P. Ltd. (supra) was a case in which the Assessee had obtained lease of premises over a period of 39 years in which there was a old building ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... pra) was also a case in which a Private Limited Company was running a hospital in a leased premise, on which premise maintenance was carried out. The Assessing Officer treated it as a capital expenditure. The High Court held that though the building belonged to the Directors, the owners were separate entities returning the rental income and also paying tax on the profits arising out of the hospita ..... X X X X Extracts X X X X X X X X Extracts X X X X
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