Judgment Search Results Home > Cases Phrase: border security force act 1968 section 17 mutiny Court: income tax appellate tribunal itat delhi Year: 2007 Page 1 of about 6 results (0.208 seconds)

Bhp Minerals International Vs. Deputy Director of Income-tax

Court : Income Tax Appellate Tribunal ITAT Delhi

..... ), wherein the assessee was held to be entitled to expenditure incurred holding that the assessee has commenced its business in india from 13-4-1981, when it secured and accepted the letter of intent from neyveli lignite corporation and not from october, 1981 when it opened its site office, is of no assistance to the ..... though incurred wholly and exclusively for the purpose of the business may nevertheless be inadmissible as an allowance, if it is of a capital nature. the border line between a capital expenditure and a revenue expenditure is a blurred one.different minds may come to different conclusions and may yet have valid reasons justifying each ..... assessment year 2000-01, the commissioner (appeals) has wrongly disallowed the claim of the assessee merely placing reliance on the provisions of section 35(e) of the act which are not applicable to the case of the assessee, firstly, because the assessee was a foreign company whereas this section was only applicable to the indian companies .....

Pradeep Agencies-joint Venture Vs. Income Tax Officer

Court : Income Tax Appellate Tribunal ITAT Delhi

Reported in : (2007)111TTJ(Delhi)346

..... the members of an aop or boi [other than a company or a co-operative society or a society registered under the societies registration act, 1860 (21 of 1860) or under any law corresponding to that act in force in any part of india) in the whole or any part of the income of such association or body are indeterminate or unknown, tax ..... court to direct that a circular should be given effect to and not the view expressed in a decision of the supreme court or the high court. we find great force in this submission made by the learned senior advocate for the revenue and find absolutely no merit in this appeal and the same stands dismissed, but in the circumstances ..... 10. considering these submissions learned cit(a) observed that the jv was entered into with the object to carry on business to act as an agent to m/s ril as sales and service representative for promotion and to secure order for its product pta. he analyzed the terms of jv agreement. he also analyzed the various activities carried out by .....

Smt. Krishna Verma Vs. Assistant Commissioner of Income

Court : Income Tax Appellate Tribunal ITAT Delhi

Reported in : (2007)107ITD1(Delhi)

..... note that return once filed under section 158bc(a) of the act cannot be revised (refer second proviso thereto). therefore, in a case where the assessee has not been granted sufficient time to furnish a return as prescribed under the law, such assessee is forced to file his return within the time prescribed and such person ..... capacity, which may be dispensed with without infringing any public right or public policy. in other words, if the statutory conditions are inserted simply for the security or benefit of the party to the proceeding and no public interests are involved, such conditions will not be considered as indispensable and either party may waive ..... capacity, which may be dispensed with without infringing any public right or public policy. in other words, if the statutory conditions are inserted simply for the security or benefit of the party to the proceeding and no public interests are involved, such conditions will not be considered as indispensable and either party may waive .....

Amadeus Global Travel Vs. Dy. Commissioner of Income-tax

Court : Income Tax Appellate Tribunal ITAT Delhi

Reported in : (2008)113TTJ(Delhi)767

..... year 1996-97, the taxability will have to be decided in accordance with the provisions of the act only. the assessee is admittedly tax resident of spain. the convention for avoidance of double taxation with spain (treaty) came into force with effect from 12th january 1995. however, article 30(2) of the treaty (p. 152/ ..... the nature of preparatory or auxiliary activities. further, amadeus india has been habitually entering into subscriber agreement with travel agent etc., which in substance tantamounts to securing of orders for the assessee's crs.it is clear that amadeus india has been habitually concluding contracts with subscribers in india on behalf of and with ..... a particular territory only fixed by the company; (iv) payment of commission and allowance to the dealer by the company at its sole discretion; (v) furnishing security for performance as per the stipulation in the contract. it was held by the apex court that the aforesaid restrictions were necessary in order for the company to .....

Ms Mayawati Vs. Dy Commissioner of Income-tax

Court : Income Tax Appellate Tribunal ITAT Delhi

Reported in : (2008)113TTJ(Delhi)178

..... material.14.1. to conclude, the transactions of loan have no connection with the gifts made. secondly, the assessee was in no way involved in the matter for securing the above mentioned loans, nor has she repaid the same. in such facts and circumstances of the case the genuineness of the gift cannot be suspected or doubted by ..... not only the burden but also the onus cast on him. on the other side the ao has failed miserably to lead any evidence in support of his claim, forcing me to conclude that the assessment is based on conjectures and surmises.4.17. the learned cit (appeals) thereafter considered the gift of property of c-58, inder ..... patridge v. cobb (1). in english law the term 'consideration' bears the meaning given to it in the classical judgment of currie v. misa (2). although indian contract act does not say that consideration must be good or valuable to sustain a contract, it has, however always been understood that consideration means something which is of some value and .....

Galileo International Inc. Vs. Dcit

Court : Income Tax Appellate Tribunal ITAT Delhi

..... is to grant relief in respect of income on which income-tax has been paid both under the act and income-tax in that country; or avoid double taxation of income under the act and under the corresponding law in force in that country.the learned ar cited that in the case of wipro supra, wherein it was observed ..... agreements clearly establish that galileo is not only assessee's agent, but it is economically wholly dependent on it. the subscriber's rights vis-a-vis the airlines are secured in the participation agreement to which it is not a party. similarly, distribution agreement (clause 15.3, pg. 124/apb) between the assessee and galileo india indemnifies ..... enterprise and some additional activities conducted in that state on behalf of the enterprise have contributed to the sale of the goods or merchandise; or (c) he habitually secures orders in the first-mentioned state, wholly or almost wholly for the enterprise. 5. an enterprise of a contracting state shall not be deemed to have a permanent .....