Court : Income Tax Appellate Tribunal ITAT Chandigarh
Reported in : (1996)57ITD385(Chd.)
..... w.e.f. 1-4-1989 and was subsequently omitted by the finance act, 1992 w.e.f. 1-4-1993.section 206c was also enacted by the finance act, 1988. at the time section 44ac was omitted from the income-tax act, section 206c was amended by the finance act, 1992 w.e.f. 1 -4-1992. after sub-section (8), an explanation was inserted. the word ..... purchase and sale of country liquor and english wine. return of income was filed declaring total income at rs. 1,58,836. accounting year ended on 31 st march, 1992. the assessee-firm had three licences, one relating to the indian made foreign liquor (l-2), the second for selling country liquor on wholesale basis (l-13) and ..... cit(a), however, took a different view on the ground that the income was assessable by applying the presumptive rate of profit as specified in section 44ac of the act. the cit(a) took the view that the assessee had maintained a combined trading and profit and loss account in connection with the business conducted under three different .....
Tag this Judgment!Court : Income Tax Appellate Tribunal ITAT Chandigarh
Reported in : (1996)56TTJ(Chd.)252
..... w.e.f. 1st april, 1989, and was subsequently omitted by the finance act, 1992, w.e.f. 1st april, 1993. sec. 206c was also enacted by the finance act, 1988. at the time s. 44ac was omitted from the it act, s. 206c was amended by the finance act, 1992, w.e.f. 1st april, 1992. after sub-s. (8), an explanation was inserted. the word "buyer" ..... of purchase and sale of country liquor and english wine. return of income was filed declaring total income at rs. 1,58,836. accounting year ended on 31st march, 1992. the assessee-firm had three licences, one relating to the indian made foreign liquor (l-2), the second for selling country liquor on wholesale basis (l-13) and ..... cit(a), however, took a different view on the ground that the income was assessable by applying the presumptive rate of profit as specified in s. 44ac of the act. the cit (a) took the view that the assessee had maintained a combined trading and profit and loss account in connection with the business conducted under three different .....
Tag this Judgment!Court : Income Tax Appellate Tribunal ITAT Chandigarh
Reported in : (2003)86ITD291(Chd.)
..... ample evidence in the statute itself to show that the quantum of deduction provided by sub-section (3) for several years was not considered sufficient and through amendment made by finance act, 1992, it has been thought proper by legislature to increase the amount of deduction by 90 per cent of sums referred to in clauses (iiia), (iiib) & (iiic) of section 28 of ..... on merit. he held that excise duty was not to be included in the "total turnover" while computing relief under section 80hhc of the income tax act.a similar order was passed for assessment year 1992-93. the proceedings initiated under section 147/148 were held to be illegal and without jurisdiction and relief even on merit was allowed to the assessee .....
Tag this Judgment!Court : Income Tax Appellate Tribunal ITAT Chandigarh
Reported in : (2001)77ITD108(Chd.)
..... bid money in an auction or, as the case may be, the highest accepted offer in case of tender or any other mode. the said provisions were omitted by the finance act, 1992 w.e.f. 1-4-1993. as a result, the provisions of section 206c were also suitably amended. it may be mentioned that under section 206c, the liability is ..... on a trade or business, such a charge is the normal incident of a trading or business transaction. (iv) with reference to the explanation to section 206c as inserted by finance act, 1992, the cit(a) opined as follows :- in my opinion, it is clear that the explanation creates two distinct types of buyer i.e. (i) a person who obtains ..... then stood and not advancing revenue's case whereas ramjee prasad sahu's case (supra) dealt with the provisions of section 206c as were introduced by the finance act, 1992 w.e.f. 1-4-1992 holding that 15% of the excise duty payable by the petitioners on account, of purchase of country liquor could not be collected as income-tax under section .....
Tag this Judgment!Court : Income Tax Appellate Tribunal ITAT Chandigarh
Reported in : (2000)77ITD108(Chd.)
..... in an auction or, as the case may be, the highest accepted offer in case of tender or any other mode. the said provisions were omitted by the finance act, 1992 with effect from 1-4-1993. as a result, the provisions of section 206c were also suitably amended. it may be mentioned that under section 206c, the liability ..... on a trade or business, such a charge is the normal incident of a trading or business transaction." (iv) with reference to the explanation to section 206c as inserted by finance act, 1992, the commissioner (appeals) opined as follows : "in my opinion, it is clear that the explanation creates two distinct types of buyer i.e. (i) a person who ..... stood and not advancing revenues case whereas ramjee prasad sahu's case (supra) dealt with the provisions of section 206c as were introduced by the finance act, 1992 with effect from 1-4-1992 holding that 15 per cent of the excise duty payable by the petitioners on account of purchase of country liquor could not be collected as income .....
Tag this Judgment!Court : Income Tax Appellate Tribunal ITAT Chandigarh
Reported in : (2004)88ITD445(Chd.)
..... interest paid by a firm to a partner was totally disallowed under section 40(b) of the income-tax act till assessment year 1992-93. however, w.e.f. 1-4-1993 changes have been made in the income-tax act by the finance act, 1992 allowing interest and remuneration to partners and working partners as per clauses (iv) & (v) of section ..... 40(&) of the income-tax act. clause (v) is relevant for our purposes and is reproduced as below :- (v) any payment of ..... that during the course of hearing of appeal, the assessee raised an additional ground of appeal relating to-charging of interest under section 234b of the income-tax act. it was contended that the assessee objected to charging of interest under the above provision as per ground no. 6 raised before the learned commissioner of income-tax .....
Tag this Judgment!Court : Income Tax Appellate Tribunal ITAT Chandigarh
Reported in : (2004)90ITD569(Chd.)
..... towards meeting the cost of foreign travel to the doctors. vi) it was pointed out that sub-section 4a of section 11 was amended by finance act (no. 2) of 1992 w.e.f. 1.4.1994, where it has been laid down that provisions of sub-sections (1), (2), (3) or (4 ..... help to deserving faculty members, trainees and/or patients therein. clauses (ii) and (iii) of article a further provide as under: (ii) to maintain, establish, finance, subsidise, exclusively or partly, or give grants-in-aid, recurring or otherwise for the maintenance of hospitals, clinics, dispensaries, nursery schools or other establishments of like nature." ..... medical education & research, chandigarh, grant research stipends, scholarship or provide help to deserving faculty members, trainees and/or patients therein and further to maintain, establish, finance, subsidize,m exclusively or partly, or give grants-in-aid, recurring or otherwise, for the maintenance of hospital, clinics, dispensaries, nursery schools or other establishments .....
Tag this Judgment!Court : Income Tax Appellate Tribunal ITAT Chandigarh
Reported in : (2005)3SOT861(Chd.)
..... the cbdt for the purpose of deduction under section 80-o in earlier years. no such approval was required after the amendment was made by the finance act, 1991, with effect from 1-4-1992.he then referred to section 80hhb. he brought to our attention sub-section (5) of this section in which it is provided that against the ..... are of the considered opinion that the assessee would have liberty to claim deduction under any provision chosen by it because both the provisions remained in the act. before the amendment made by the finance act, 1997 with effect from 1-4-1998, section 80-o was also available for "any income by way of royalty, commission, fees or any ..... line of thinking by urging that 'professional services' have been brought within the scope of section 80-o only by an amendment by the finance (no. 2) act, 1991, and that too, with effect from 1-4-1992, which is proposing to substitute the words 'technical or professional services' in place of the words 'technical services' now used in the .....
Tag this Judgment!Court : Income Tax Appellate Tribunal ITAT Chandigarh
Reported in : (1995)52ITD426(Chd.)
..... part of the total turnover. it was also pointed out that the expression 'the whole of the income' was substituted by 'profit' inserted by the finance act, 1991, w.e.f. 1-4-1992 with a view to curbing certain unethical practices adopted by the assessees. it was also submitted that the total turnover ultimately upheld by the learned cit( ..... return for assessment year 1992-93, showed total turnover at rs. 96,17,49,925 as per the following details :- 3. export incentives ..... dated 10-1-1994 passed by the cit(a) (central), ludhiana, for assessment year 1992-93. the only issue involved in this appeal is whether the revenue authorities were justified in reducing the claim of the assessee under section 80hhc of the income-tax act, 1961.2. brief facts of the case are these : the assessee-company, in its .....
Tag this Judgment!Court : Income Tax Appellate Tribunal ITAT Chandigarh
Reported in : (2004)91TTJ(Chd.)1044
..... meeting the cost of foreign travel to the doctors.(vi) it was pointed out that sub-section (4a) of section 11 was amended by the finance (no. 2) act of 1992 with effect from 1-4-1994, where it has been laid down that provisions of sub-sections (1), (2), (3) or (4) ..... in the definition of 'charitable purposes'. as per clause (ii) of article 4 of the assessee-trust, its objects, inter alia, included to maintain, establish, finance, subsidize, exclusively or partly, or give grants-in-aid, recurring or otherwise, for the maintenance of hospitals, clinics, dispensaries, nursery schools or other establishments of like ..... medical education & research, chandigarh, grant research stipends, scholarships or provide help to deserving faculty members, trainees and/or patients therein, and further to maintain, establish, finance, subsidize, exclusively or partly, or give grants-in-aid, recurring or otherwise, for the maintenance of hospital, clinics, dispensaries, nursery schools or other establishments of .....
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