Court : Income Tax Appellate Tribunal ITAT IT
..... 90/sc, dated december 3, 1991, to examine legal issues arising from the amendments made to chapter xixa of the income-tax act, 1961, and corresponding provisions of the wealth-tax act, 1957, by the finance act (no. 2), 1991. vide notification dated december 20, 1991, the chairman, settlement commission, directed that, in order to determine ..... the late return, interest chargeable for defaults in payment of advance tax and interest chargeable for deferment of advance tax.this power was given to the central board of direct taxes, declared as an income-lax authority under section 116 and was, therefore, exercisable by the settlement commission which, in view of ..... given to the settlement commission the same administrative powers for issue of instructions to subordinate authorities for the proper administration of the income-tax act as are available to the central board of direct taxes. suffice it to say that, presently, for reasons mentioned above, there is no scope for the commission to .....
Tag this Judgment!Court : Income Tax Appellate Tribunal ITAT Delhi
..... be validated by a subsequent amendment. 7.17. at this stage it is appropriate to note that sub-sec. (2b) has been inserted by the finance act, 2012, whereas sub-sec. (2a) by the finance act, 2011. we have noticed above that by means of insertion of sub-sec. (2a), the tpo gets power to determine alp in respect of ..... any one or more of such enterprises." 14.12. after sub-section (1), there is sub-section (2) followed by the explanation with two clauses, inserted by the finance act, 2012 w.r.e.f. 1.4.2002 starting with the expression: `for the removal of doubts'. clause (i) of the explanation provides that the expression `international transaction' shall ..... indian tax base by multi-nationals through a mechanism of what is known as "transfer pricing" . in a modern democratic set up, the governments - local, state or central - are modified version of 'service corporations' of which all the people in the community are the members and the principle object of the government is to serve the people .....
Tag this Judgment!Court : Income Tax Appellate Tribunal ITAT IT
..... opportunity of hearing as required by the provisions of the first proviso to section 245d(1). when the said application was pending, on april 1, 1979, the finance act, 1979, inserted sub-section (1a) after section 245d(1), which empowered the settlement commission to overrule the objections of the commissioner. on may 29, 1979, ..... right to raise objections against the settlement commission proceeding with an application has been withdrawn." it was submitted that, after the finance (no. 2) bill, 1991, had received the assent of the president, the central board of direct taxes had issued' the "press release" wherein it was stated that "the new procedure" would facilitate ..... existing procedures" were causing unnecessary delays and that, therefore, sub-section (1a) of section 245d was proposed to be deleted. (v) "press release" issued by the central board of direct taxes dated october 1, 1991, which inter alia, reads as under (see [1991] 191 itr (st.) 196) : "in order to facilitate quicker .....
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