Judgment Search Results Home > Cases Phrase: income tax act 1961 chapter viii rebates and reliefs Sorted by: recent Court: income tax appellate tribunal itat delhi Page 1 of about 6 results (0.220 seconds)

Sony India (P) Limited Vs. Deputy Commissioner of Income Tax

Court : Income Tax Appellate Tribunal ITAT Delhi

..... passed by the ld. tpo without recording any cogent reasons for the same. 6. that on facts and in law the cit(a) erred in upholding addition to income of rs. 400,660,016 under chapter x of the income tax act, 1961. 7. that on facts and in law, the assumption of jurisdiction by ao/tpo to determine arm's length price is ..... bad in law and void ab-initio. 8. that on facts and in law the cit(a) erred in upholding the modified arm's length price. 9. that ..... such transactions in the open market; or (ii) reasonably accurate adjustments can be made to eliminate the material effects of such differences. further "rule 10b(1)(e) of income tax act providing for determination of arm's length price under section 92c required that following steps are to be taken while applying tnmm after selection and evaluation of controlled transactions. it .....

Moonbeam Finvest Lease Ltd. Vs. Ito

Court : Income Tax Appellate Tribunal ITAT Delhi

..... the assessee vide letter dated 1-7-2005 and thereafter reassessment was completed vide impugned assessment order dated 31-10-2005 passed under section 143(3)/147 of income tax act, 1961. the copy of reasons as supplied by the assessing officer vide letter dated 1-7-2005 are as under: original assessment in this case was completed ..... reassessment proceedings so framed are invalid and bad in law. 6. that the condition as laid down under sub-section (-1) of section 151 of the income tax act for the issuance of notice under section 148 has not been complied with by assessing officer and accordingly the notice under section 148 as issued by assessing officer ..... is not sustainable under the law. 4. that there was no valid material available with the assessing officer to assume jurisdiction under section 147/148 of the income tax act and accordingly the notice, as issued by the assessing officer under section 148 and the reassessment so made in furtherance of such initiation is invalid and liable .....

Moonbeam Finvest Lease Ltd. Vs. Income Tax Officer

Court : Income Tax Appellate Tribunal ITAT Delhi

Reported in : (2008)115TTJ(Delhi)510

..... the part of the assessee to disclose truly and fully all material facts necessary for its assessment for this year, the income chargeable to tax has escaped assessment within the meaning of section 147 of the act. approval to issue notice under section 148 may be granted accordingly.5. after receiving reasons the assessee objected to the reassessment ..... assessee vide letter dt. 1st july, 2005 and thereafter reassessment was completed vide impugned assessment order dt. 31st oct., 2005 passed under section 143(3)/147 of it act, 1961. the copy of reasons as supplied by the ao vide letter dt. 1st july, 2005 are as under: original assessment in this case was completed under section 143 ..... is made, no action shall be taken under section 147 after the expiry of 4 years from the end of the relevant assessment year, unless any income chargeable to tax has escaped assessment for that very year by reason of the failure on the part of the assessee to disclose fully and truly all material facts necessary .....

Maruti Udyog Limited Vs. Jt. Cit, Spl. Range 6

Court : Income Tax Appellate Tribunal ITAT Delhi

Reported in : (2006)285ITR228(Delhi)

..... tribunal was that whether brought forward losses can be set off while determining business profits for the purpose of computing deduction under section 80hhc of the income-tax act, 1961, and not whether brought forward unabsorbed depreciation can be deducted in arriving at the business profits for the purpose of computing deduction under section 80hhc.hence ..... be deducted for the purpose of computing profits of the business as provided in explanation (baa) below sub-section (4-c) in section 80hhc of the income-tax act, 1961.for this contention, the ld. authorized representative for the assessee relied on the decision of the delhi, 'a' bench of the tribunal in the case ..... to be computed by applying provisions of section 28 to 44-d of the income-tax act, 1961. thus, while computing the business income, depreciation has to be deducted as per section 32 of the act.since section 32(2) of the act specifically provides for treating earlier years unabsorbed depreciation as a part of the current .....

Mentha and Allied Products Pvt. Vs. Income-tax Officer

Court : Income Tax Appellate Tribunal ITAT Delhi

Reported in : (1992)43ITD33(Delhi)

..... was raised to press this application probably because of the retrospective amendment of the income tax act, 1961, by the finance act, 1990, with the result that such amounts have specifically been included in the definition of income in section 2(24} of the income-tax act, 1961. we, therefore, reject the application for admission of the additional ground and, ..... had held that amounts received by an assessee on account of cash compensatory support were not trading receipts and were, therefore, not taxable under the income-tax act, 1961. the tribunal observed that the cash compensatory support is received by an exporter in its capacity as a registered exporter and such receipts could not ..... (india) (p.) ltd. v. iac [1988] 25 itd 193 (delhi), was not a trading receipt and was, therefore, not taxable under the income-tax act, 1961. there the tribunal held that the cash compensatory support was received by an exporter in its capacity as a registered exporter and such receipts could not be .....

Godore Tools (India) (P.) Ltd. Vs. Inspecting Assistant

Court : Income Tax Appellate Tribunal ITAT Delhi

Reported in : (1988)25ITD193(Delhi)

..... that though the ccs could not be treated as a mere bounty or gift, it was not a revenue receipt taxable under section 28(iv) of the income-tax act, 1961 taut only a capital receipt given to improve and build up its capital base and to remove the inadequacies in its export apparatus or infrastructure. we agree ..... or in a different state, in the absence of any contrary decision of any other high court. the appellate tribunal is not an income-tax authority as defined in section 116 of the income-tax act, 1961. both the parties are, therefore, free to canvass their respective viewpoints before the special bench regarding the ratio decidendi of the various decisions ..... of two benches of the tribunal that it was considered fit and proper by the president to constitute the present special bench under section 255(3) of the income-tax act, 1961.the position as clarified by the third member in the case of export house (supra) namely that when conflicting decisions are there, the decision of the special .....