The dispute between the parties concerns the cost of construction of a 14 km long 36” diameter pipeline from the Hazira Field to Mora village in the sum of Rs. 93.27 crores which Niko claims is part of ‘development cost’ which it is entitled to recov..
This is an appeal from a judgment, dated 5th February, 2003, rendered by the High Court of Delhi at New Delhi in CWP No.2278/2002. By the impugned judgment, the High Court has upheld the validity of the Delhi Race Course Licensing (Amendment) Rules, ..
The assessee companies in the present cases along with some other entities were promoters of a company namely M/s. Dawn Mills Co. Ltd. and were holding 52.60 percent shares of the said company. They agreed to transfer their shares and controlling int..
Both sides would agree that the issues raised and the relief sought for in this appeal are identical with the issues raised and considered by this Court in the case of Union of India Vs. Giani in Civil Appeal No.1884/2011 on February 17, 2011. 5. In ..
Although all these appeals have been filed by the revenue however the ld. AR submitted that under Rule 27 of Income Tax (Appellate Tribunal) Rules, 1963, assessee wants to support order on the ground of reopening decided against the assessee by the C..
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..
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