The relevant material facts are like this. The assessee before us, Dongfang Electric Corporation (DEC, in short) is a non-resident company - incorporated under the laws of, and fiscally domiciled in, the People’s Republic of China. The assessee had f..
It is, thus, evident that DTAA recognizes the fact that the amendments made in the IT Act are not affected in so far or they are not in conflict with the specific provisions of the DTAA. Therefore we are of the view that the amendment made in sect..
Facts, in brief, as per the relevant orders are that return declaring income of `.39,90,410/- was filed by the assessee on 18th July, 2006. Subsequently on 26th April, 2007, a search u/s 132 of the Income Tax Act 1961, (hereinafter referred to as the..
Adverting first to ground no.1 in the appeal , facts, in brief, as per relevant orders are that e-return declaring income of ``28,24,41,510/- filed on 29.09.2008 by the assessee, a foreign company having permanent establishment in India, was selected..
Briefly stated facts are that the AO has computed the interest u/s. 244A of the Act on the refundable amount without considering the interest incomes credited earlier in the tax computation statement as per the appeal effect order dated 21.06.2010. I..
The undisputed facts are that the plaintiff, M/s York Export Ltd., and the defendants entered into an agreement whereby the defendants agreed to sell and the plaintiff agreed to purchase 164 bighas 7 biswas of land owned by the defendants comprised ..
It was the submission by the ld. AR that the show cause notice issued u/s 263 of the IT Act on 23.01.2012 had not mentioned which order was erroneous nor had he mentioned the error in the assessment order. It was the submission that the show cause no..
Facts, in brief, as per relevant orders are that e-return declaring income of ``32,780/- filed on 21.11.2006 by the assessee, engaged in the business of manufacturing and trading in home furnishing, after being processed u/s 143(1) of the Income-tax ..
The Income Tax authorities made re-assessments on 28.12.2007. The order was carried in Appeal. The Appellant had objected to the assumption of jurisdiction under Section-147 of the Act by the A.O. and also objected to the addition of certain amounts ..
By way of this appeal, the Assessing Officer has challenged correctness of Commissioner of Income Tax (Appeals)’s order dated 04.11.2011 in the matter of order u/s. 154 r.w.s. 143(3) of the Income Tax Act, 1961, for the assessment year 2005-06. The a..
The aforesaid appeals had been filed on behalf of the Supreme Court Bar Association and its then Honorary Secretary, Mr. Ashok Arora, and Ms. Sunita B. Rao, Coordinator, Implementation Committee of the Supreme Court Bar Association, against an interi..
Having regard to Rule 19(2) of ITAT Rules, 1963 and following various decision of the Tribunal including in the case of C.I.T. vs. Multiplan India (P) Ltd., reported in 38 ITD 320 (Del.) and the judgement of Hon’ble Madhya Pradesh High Court in the c..
This petition has been filed under Sections 391 to 394 of the Companies Act, 1956 (the Act) by Sony India Private Limited (hereinafter referred to as petitioner/transferor company), in respect of a scheme of arrangement (scheme for short) between the..
I have carefully considered the assessment order and the submissions made by the ld. AR in this regard. As per the facts of this case, the appellant company is a 100% subsidiary of the holding company M/s McCann-Erickson (India) Pvt. Ltd. M/s McCann ..
Brief facts are that the assessee is a cooperative society engaged in the construction of about 476 flats. It has claimed that due to dispute between different groups of members, complaints were made for violation of cooperative group housing society..
At the time of hearing the ld. Counsel appearing on behalf of assessee has submitted a copy of the adjournment petition made before ld.CIT(A) dated 09.02.2011 and submitted that the ld. CIT(A)’s observations that no applications for adjournment were ..
That without prejudice to Ground No. 1 above , the l earned Commissioner of Income Tax erred in holding that the Assessing Of f ice r failed to consider the applicability of provisions of sect ion 115JB of the Income Tax Act , 1961 when the tax payab..
That the Ld. CIT(A) was unjustified in confirming the addition of Notional Interest of Rs.7.18 Crore allegedly due from M/s. V. B. Desai & Co. without any cogent reasons. 1.1. That the Ld. CIT(A) failed to appreciate that after the judgment of the Sp..
Mr. Pamaljeet Singh is sole proprietor of M/s Friends Overseas (plaintiff). In fact, sole proprietorship firm has no separate legal entity and is a creation of its sole proprietor, thus, any reference made to sole proprietorship firm shall mean and i..
Petitioner seeks permission to withdraw the writ petition with liberty to file a fresh petition after impleading all the necessary parties. Permission, as above, is granted...
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