Court : Income Tax Appellate Tribunal ITAT Chandigarh
Decided on : Feb-28-2006
Reported in : (2006)103TTJ(Chd.)684
..... received by it from the lease of the machinery was to be treated as profits attributable to the priority industry and hence would qualify for deduction under section 80-1 of the i.t. act, 1961, was accepted by the ito. the addl. commissioner, however, held that the assessee was not entitled to the relief and revised the order of ..... to the issue related to the lease rental income of rs. 90,000/- is concerned, the facts in brief are that the assessee claimed deduction under section 80ia/ib of income-tax act on lease rent amounting to rs. 90,000/- in unit-ii. the assessing officer did not allow the deduction by stating that the lease rent had ..... production but not vice-versa. their lordships of the hon'ble apex court in the case of cit v. n.c.budhiraja & co. while considering the provisions of section 80hh of the income-tax act and had held as under: that the word "production" has a wider connotation than the word "manufacture". every "production" may not amount to "manufacture" whereas every .....
Tag this Judgment!Court : Income Tax Appellate Tribunal ITAT Chandigarh
Decided on : Mar-22-2006
Reported in : (2007)105ITD52(Chd.)
..... application of mind to the same set of facts or merely a change of opinion which did not confer jurisdiction on the assessing officer to reassess income under section 147 of the act.according to the learned cit (appeals), all the primary facts were disclosed and there was no omission or failure on the part of the assessee to ..... which was not already part of the record at the time of original assessment. the learned cit (appeals) was of the view that the parameters laid down under section 147 of the act were not satisfied in the present case. reliance was placed on the following case laws: (i) cit v. kelvinator of india ltd. [2002] 256 itr 1 ..... court in the case of swaraj engine ltd. (supra) had held as under: an income-tax officer acquires jurisdiction to reopen an assessment under section 147(a) read with section 148 of the income-tax act, 1961, only if on the basis of specific, reliable and relevant information coming to his possession subsequently, he has reasons, which he must record .....
Tag this Judgment!Court : Income Tax Appellate Tribunal ITAT Chandigarh
Decided on : Apr-24-2006
Reported in : (2007)106TTJ(Chd.)250
..... concluded that the amount of rs. 19,48,000 is a deemed dividend. before reaching to a conclusion, we are supposed to analyse sub-clause (e) of section 2(22) of the act which is reproduced herewith: any payment by a company, not being a company in which the public are substantially interested or any sum (whether as representing a part ..... of the company to give a loan. the learned departmental representative during arguments has not disputed the first three conditions and stressed about condition no. (iv) of section 2(22)(e) of the act. the learned cit(a) has also found that the amount in question was given by m/s super woollen (p) ltd. and if was a transfer ..... business of manufacturing and trading of knitted fibres and manufacturing and export of readymade garments. the main issue in the present appeal is whether deemed dividend under section 2(22)(e) of the act were given to the assessee-firm by a sister-concern, m/s ariel exports (p) ltd. the said firm advanced money to the assessee from time .....
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