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Commissioner of Income Tax Vs. Concord Pharmaceuticals

Court : Gujarat

Subject : Direct Taxation

Acts : Income Tax Act, 1961 - Sections 2, 3, 4, 37(4), 90, 90(2), 119, 253(2), 260A, 263, 268A, 268A(1), 268A(4), 268A(5) and 275(1); Finance Act, 2008; Kerala General Sales Tax Act, 1963 - Sections 3(1A) and 60; Income Tax Rules - Rule 47; Income Tax Appellate Tribunal Rules, 1963 - Rules 6 to 15

Reported in : (2008)220CTR(Guj)117; [2009]317ITR395(Guj)

is also contended that the CBDT Instruction No. 1985, dt. 29th June, 2000 clarifies the Instruction No. 1979/F. No. 279/126/1998-ITJ, dt. 27th March, 2000 and … the status of residence as well as beneficial ownership of shares, is a circular within the meaning of Section 90, and, therefore, it must have the legal consequences contemplated by Section 90(2). In other words, the circular will … also taken into account. The Board has also clarified that where a question of law arises for the first time before the High Court concerned, it should be contested irrespective of revenue involved. Where an adverse judgment … Nos. 1402 to 1405 of 2007 under Section 260A of the IT Act 1961 for asst. yrs. 1995-96 and 1996-97 proposing to formulate the following

Star Trading Vs. Commissioner of Income Tax

Court : Kerala

Subject : Direct Taxation

Acts : Income Tax Act, 1961 - Sections 245(4), 245C, 245D, 245D(1), 245D(4), 245F(2) and 251; Finance (No. 2) Act, 1998 - Sections 90, 90(1), 90(2), 90(4), 95 and 95(1)

Reported in : (2008)220CTR(Ker)511

is later that the CIT by Ext. P2 order dt. 30th Oct., 2000, cancelled the same for reasons stated in the order, which is impugned … does not extend to cancel the certificate as such. Admittedly, this is not a case to attract the first proviso. If so, in the factual situation, the CIT has no power to cancel the certificate issued in … namely, CIT. The designated authority, after processing the application, passed Ext. P1 order dt. 26th Feb., 1999 under Section 90(1) of the Finance (No. 2) Act, 1998 determining the amount payable by the declarant towards the full and

Babros Machinery Mfrs. (P) Ltd. Vs. Deputy Commissioner of Income Tax

Court : Income Tax Appellate Tribunal ITAT Ahmedabad

Subject : Direct Taxation

Reported in : (2003)84ITD91(Ahd.)

Court in the case of CST v. H.M. Esufali H.M. Abdulali (1973) 90 ITR 271 (SC), has held that estimate can be made on the … is asst. yrs, 1986-87 to 1995-96 and 1st April, 1995 to 8th Sept., 1995.3. In respect of the first point of difference, the facts as noted by the AO are as under: "Undisclosed income for asst. yr. … the AO who is Dy. CIT(A) Special Range-2, Ahmedabad, under Section 158BD r/w Section 158BC(c) of the IT Act, 1961 for the Block Period asst. yrs. 1986-87 to 1995-96 and 1st April, 1995 to 8th Sept., 1995.2.

Wipro Limited Vs. Deputy Commissioner of Income Tax

Court : Income Tax Appellate Tribunal ITAT

Subject : Direct Taxation

Reported in : (2005)96TTJ(Bang.)211

Explanation to Section 80HHE of the IT Act, 1961 (43 of 1961), the CBDT hereby specifies the following information technology enabled products or services, as the case may be, for the purpose of said clauses, namely : includes … that part of the income which may be taxed in the United States.Sri K.R. Pradeep also relied on Section 90 which is extracted hereunder : (1) The Central Government may enter into an agreement with the Government of … 111, Mount Road, 98/2761 Guindy, Chennai-600Pune Wipro Ltd., CTS, 685/2B STP/P/VIII(A) 10-3-2000 2000-01 2000-01Gurgaon Wipro Ltd., Flat No.201, PCMG/PSE/5 19-3-2000 2000-01 2000-01Mysore -- -- --

Assistant Commissioner of Income Vs. Fertilizer Traders [Alongwith

Court : Income Tax Appellate Tribunal ITAT Allahabad

Subject : Direct Taxation

Reported in : (2004)83TTJ(All.)473

entries of two sets and gave the copies of printsout. It is necessary to mention that as per information supplied by the counsel for the assessee, the position of the regular returns of both the assessees are … on facts in upholding the validity of the order dt. 4th Oct., 2000 that had been passed earlier by the Dy. CIT, Central Circle, Gorakhpur … against different orders of the CIT(A)-I, Kanpur dt. 14th Aug., 2002 passed under Section 158BC/154 of the IT Act, 1961.3. In both the cases of the assessees, undisclosed income was computed and thereafter it was bifurcated in … In reply he added that he has never deposited Rs. 1,01,000, Rs. 90,200 and Rs. 93,000 and claimed that these entries are wrong because he

Deputy Commissioner of Income Tax Vs. Royal Jordanians Airlines

Court : Income Tax Appellate Tribunal ITAT Delhi

Subject : Direct Taxation

Reported in : (2006)283ITR28(Delhi)

from sovereign immunity does not extend to payment of direct taxes. However, in the absence of any specific information or evidence it is not possible to hold that the income of the assessee before us enjoys sovereign … Royal Jordanian Airlines (hereinafter referred to as "RJA") is liable to be taxed in India under the IT Act, 1961 in respect of the assessment years in question. The same issue arose in the case of the … 1. These four appeals pertain to asst. yrs. 1995-96, 1994-95, 1996-97 and 2000-2001. Appeal in ITA No. 5252/Del/1998 is Revenue's appeal filed on 3rd Nov., … in the case of the assessee in relation to assessment order under Section 143(3) for asst. yr. 1995-96. Appeal in ITA No. 3805/Del/1999 is the … AR also referred to the provisions of Section 90(2) of the Act and argued that by DTAA

Uma Polymers (P) Ltd. Vs. Deputy Commissioner of Income Tax

Court : Income Tax Appellate Tribunal ITAT Jodhpur

Subject : Direct Taxation

Reported in : (2006)284ITR1(Jodh.)

evident from above that in all the cases, except that of Shri Virendra Raj Lodha, the AO got information about account of the creditors from their respective banks. Photocopies of bank statement of creditors obtained by the … to 86 Lodha showing transaction mostly10. Smt. Sarita Confirmed copy of account 90 to 91 Lodha showing transaction mostly Note : The GIR numbers of … allowance from Rs. 7,17,800 to Rs. 5,74,950 and also added back Rs. 2,16,806 under Section 43B of the Act on account of outstanding RFC interest and other liabilities. But the AO did not entertain the second revised

Assistant Commissioner of Income Vs. Vindhya Telelinks Ltd.

Court : Income Tax Appellate Tribunal ITAT Jabalpur

Subject : Direct Taxation

Reported in : (2007)107TTJJab149

Section 148 the appellant filed the returns. The appellant also received notices under Section 143(2) calling for further information on certain points in connection with the returns. Thereupon the appellant filed writ petitions challenging the notices. The … stated to be pending.5. The notice under Section 148 dt. 23rd Oct., 2000 was issued for the reasons that: (1) Original assessment was completed under … entire assessment was bad in law. 4. The appellant is relying on decision of R.L. Narang which is actually against the appellant. The appellant is not appreciating that valid notice under Section 148 is a condition precedent … 1,75,44,375 (Rs. 77,97,500 + Rs. 97,46,875) with short levy of tax Rs. 90,79,214.6. The AO, therefore, concluded that the income had been underassessed to the

In Re: Abdul Razak A. Meman, in Re:

Court : Authority for Advance Rulings

Subject : Direct Taxation

Reported in : (2005)195CTRAAR534

of taxation of investment incomes in order to encourage flow of capital, technology and technical service from one country to the other to their mutual … interest (Article 11) and capital gains (Article 13). We, therefore propose to deal with the first question here.7. Section 90 of the Indian Act empowers the Central Government to enter into an agreement with the Government of any … does not constitute the basis for Norsk's tax liability in the first place. A factual proposition which merely informs domestic tax liability cannot constitute a residency criterion under the Canada-United States Income Tax Convention (1980). The only … been working with Abu Dhabi Islamic Bank from August, 1999 (asst. yr, 2000-01). He claims to be a resident of UAE and a non-resident in

Assistant Commissioner of Income Vs. Jaipur Stock Exchange

Court : Income Tax Appellate Tribunal ITAT Jaipur

Subject : Direct Taxation

Reported in : (2007)108TTJ(JP.)393

the assessee mainly for the reason that the assessee was allowed exemption under Section 11 for the very first year of the commencement of the activities of the assessee for the asst. yr.1988-89 by the Tribunal but … has erred in holding the assessee company as a charitable institution as per Section 2(15) of the IT Act, 1961 and directing the AO to treat the same accordingly.In ground No. 2, the Department is aggrieved that … learned CIT(A), dt. 14th July, 2003 for the asst. yrs. 1995-96 and 2000-01, respectively.The assessee has filed two cross-objections against these appeals.Since the issues in