Judgment Search Results Home > Cases Phrase: competition amendment act 2007 section 24 amendment of section 31 Sorted by: old Court: income tax appellate tribunal itat mumbai Year: 1999 Page 1 of about 9 results (0.170 seconds)

Petroleum India International Vs. Deputy Commissioner of

Court : Income Tax Appellate Tribunal ITAT Mumbai

Reported in : (2000)241ITR43(Mum.)

..... accordance with subject to the provisions of this section, a deduction of the whole of such income, in computing the total income of the assessee." the finance act, 1974, amended s. 80-o retrospectively w.e.f. 1st april, 1972, to allow deduction only with reference to the income which is received in or brought into ..... , 1985. the cbdt circular no. 387, dt. 6th july, 1984 (chaturvedi & pithisaria compendium of circulars vol. 1 p. 1382), while explaining the amendment made by the finance act, 1984, stated that the deduction was introduced primarily to stimulate flow to technology from india and that the said objective could be attained with reduced deduction on that ..... by an indian company from a foreign company in consideration for its supply of technical know-how or technical services under approved agreements.sec. 80-o was amended by the finance act, 1968, to enhance the deduction available under that section to 100 per cent of the income by way of royalties, etc. the department's circular .....

Abdulgafar A. Nadiadwala Vs. Deputy Commissioner of Income

Court : Income Tax Appellate Tribunal ITAT Mumbai

Reported in : (2000)75ITD394(Mum.)

..... outside india have been omitted. the assessment year involved in the present appeal is 1996-97.therefore, we have to deal with the section as it existed before its amendment by the finance act of 1977 (supra).32. a perusal of the section quoted above reveals that for getting a deduction under s. 80-o the assessee must have derived income by ..... amount equal to fifty per cent of the income so received in, or brought into india, in computing the total income of the assessee.31. this section had been amended by the finance act of 1977 (supra) and w.e.f. 1st april, 1998, the deduction is permissible in respect of the use outside india of any patent, invention, design or registered ..... now deal with the claim of the assessee relating to deduction under s. 80-o. it will be useful to give s. 80-o as it existed before its amendment by the finance act of 1997 (26 of 97) w.e.f. 1st april, 1998 : "sec. 80-o-deduction in respect of royalties, etc. from certain foreign enterprises-where the gross total .....

Blue Dart Express Ltd. Vs. Joint Commissioner of Income-tax

Court : Income Tax Appellate Tribunal ITAT Mumbai

Reported in : (2000)75ITD414(Mum.)

..... the services even if the foreign recipient of the services utilises benefit of such services in india. it may be stated that prior to the amendment of section 80-o by finance (no. 2) act, 1991 w.e.f. 1-4-1992 the condition of approval of agreement by the board/chief commissioner or dg, as the case may ..... went on to observe further that the substitution of the expression 'technical services' by the expression 'technical or professional services' w.e.f. 1-4-1992 consequent to amendment of section 80-o is 'only clarificatory in nature'. having regard to the conditions laid down in section 80-o the claim of the assessee for relief under section 80 ..... apex court in shree manjunathesware packing products & camphor works' case (supra) was considering the question as to what constituted record in the context of section 263 of the act.this issue is not relevant in the case of the assessee. further the decision of madras high court in south india shipping corpn. ltd.'s case (supra) is distinguishable .....

Birla at and T Communication Ltd. Vs. Joint Commissioner of Income-tax

Court : Income Tax Appellate Tribunal ITAT Mumbai

Reported in : (2001)77ITD142(Mum.)

..... realising the difficulties which the assessees were facing where the payment of the fees has been made prior to the setting up of the telecom business, section 35abb was amended by the finance act, 1999, with retrospective effect from 1-4-1996 to provide that irrespective of the fact that the payment of the licence fees had been effected prior to the ..... that the arrears of the claim could also be made in the return filed for the assessment year 1997-98. the section was amended by the finance act, 1999, with retrospective effect from 1-4-1996 and after the amendment, the relevant portion of the section stood as under : "35abb. expenditure for obtaining licence to operate telecommunication services. --(1) in respect of any .....

Birla at and T Communication Ltd. Vs. Joint Commissioner of Income Tax

Court : Income Tax Appellate Tribunal ITAT Mumbai

..... realising the difficulties which the assessees were facing where the payment of the fees has been made prior to the setting up of the telecom business, s.35abb was amended by the finance act, 1999, with retrospective effect from 1st april, 1996, to provide that irrespective of the fact that the payment of the licence-fees had been effected prior to the ..... that the arrears of the claim could also be made in the return filed for the asst. yr. 1997-98. the section was amended by the finance act, 1999, with retrospective effect from 1st april, 1996, and after the amendment, the relevant portion of the section stood as under : 35abb. expenditure for obtaining licence to operate telecommunication services. - (1) in respect of any .....

Wall Street Construction Ltd. Vs. Deputy Commissioner of Income Tax

Court : Income Tax Appellate Tribunal ITAT Mumbai

Reported in : (2003)87ITD43(Mum.)

..... asst. yr. 1991-92 without prejudice that no income be taxed during asst. yr. 1992-93 as submitted in the relevant ground of appeal. (iv) amendment made in section 234b of it act, 1961, by finance act, 1995, by applied prospectively and accordingly interest under said section for asst. yr. 1992-93 be limited into the date of passing an intimation under section ..... 143(l)(a) of the said act." (v) the appellant craves liberty to add, to amend, or alter any of the above grounds of appeal." 5. the main issue in this appeal is the action of the ao in rejecting the ..... considered view, the accounts books of the assessee are liable to be rejected for the following reasons : (i) as a result of two search operations under section 132 of the it act, 1961 on 21st aug., 1990, and on 24th dec., 1992, a computer sheet was found, which gave details of 'on money' receipts and the assessee himself offered the .....

Jost'S Engg. Co. Ltd. Vs. Deputy Commissioner Of Income Tax

Court : Income Tax Appellate Tribunal ITAT Mumbai

Reported in : (2000)74ITD34(Mum.)

..... that the tax audit report had been obtained only after a substantial delay after the specified date. it is also pleaded that the abovementioned proviso has also been subsequently amended by the finance act, 1995, w.e.f. 1st july, 1995, and the proviso as it stands today requires the furnishing of the audit report before the specified date which, it ..... also observe that the ao has levied only minimum penalties as mentioned in s. 271b. we may also mention that we do not find that the subsequent amendment of s. 44ab by the finance act, 1995, w.e.f. 1st july, 1995 requiring that the tax audit report should be furnished before the specified date has any impact either way on ..... the issue before us. even before the said amendment, as per the terms of the proviso to s. 44ab, the statutory audit report and the tax audit report had .....

Savitri and Co. Vs. Income-tax Officer

Court : Income Tax Appellate Tribunal ITAT Mumbai

Reported in : (2000)74ITD225(Mum.)

..... property in question has been transferred in favour of the partners by simple book entries. in other words, the contentions is that the book entries are supported by the amendment of the partnership deed, to which we have adverted hereinbefore. it is also pleaded that from 1992 onwards, there has been a change in section 27 of the ..... the books of the firm and were offered to tax in the individual returns of the co-owners. it was pleaded before the revenue authorities that the said amendment of the partnership deed along with the book entries was of sufficient legal force to transfer the ownership of the property from the partnership firm into the hands of ..... house property that has to be assessed in respect of the income from house property under section 22 of the income-tax act and not the legal owner. it is also claimed that the amendment introduced by the finance act, 1987 relating to sections 27(iiia) and 27(iiib) are of a clarificatory nature and so have a retrospective operation. .....

Berlia Chemicals and Traders (P) Vs. Assistant Commissioner of Income

Court : Income Tax Appellate Tribunal ITAT Mumbai

..... ) 183 itr 1 (sc). in that case, the supreme court was dealing with the provisions of section 40(b) and with expln. 1 inserted by the taxation laws (amendment) act, 1984, in clause (b) of section 40. one of the arguments advanced on behalf of the assessee was that the insertion of expln. 1, though later in point ..... case also, memorandum explaining the provisions in finance (no. 2) bill, 1996, through which expln. 4a was inserted to section 43(1), makes it expressively clear that the amendment will come into effect from 1st april, 1997 and will, accordingly, apply in relation to asst. yr. 1997-98 and subsequent years. thus, expln. 4a has no application ..... the correct understanding of the provisions in section 40(b) in its application to the earlier years as well. the "notes on clauses" appended to the amending bill, however, stated that the amendment will take effect from 1st april, 1985, and will, accordingly, apply in relation to the asst. yr. 1985-86 and subsequent years. the court, .....