Court : Income Tax Appellate Tribunal ITAT Jaipur
Reported in : (2008)115TTJ(JP.)613
..... tiles for the interior and exterior decoration and designing. the assessee treated such activities as a manufacturing activity hence claimed deduction under section 80-ib of the it act, 1961 on its net profit. there is no dispute on the fact that all the other conditions as mentioned under section 80-ib have been fulfilled by the ..... he should have invited the attention of the assessee towards this deduction.32. the learned cit(a), however rejected the additional ground and such a claim on the plea that the assessee neither made any claim in the return of income nor the fact that the assessee was entitled, to the deduction under section 80hhc was ..... prayed not to admit such a claim, made before the cit(a) for the first time under section 80hhc.34. on the other hand, the learned authorised representative for the assessee mr. mahendra gargieya, vehemently argued that in this case return of income was filed declaring nil income on 2nd dec., 2003, which was originally processed under section .....
Tag this Judgment!Court : Income Tax Appellate Tribunal ITAT Jaipur
Reported in : (2003)78TTJ(JP.)330
..... high court in the case of cit v. rajasthan land development corporation (supra). their lordships has laid down five circumstances/ situations to determine whether the interest income could be assessed as "business" or income from "other sources". their lordships have laid down the following principles : "the following principles are applicable in assessing interest income under the provisions of the it act, 1961 : (i) interest on fixed deposits ..... hon'ble bombay high court in the case of cit v. punit commercial ltd. (2000) 245 itr 550 (bom) wherein their lordships observed as under : "held, that, in the instant case, section 80hhc(3)(a) of the it act, 1961, was applicable as the assessee is a 100 per cent exporter. hence, the entire business income was deemed to be profit derived from export of .....
Tag this Judgment!Court : Income Tax Appellate Tribunal ITAT Jaipur
Reported in : (2000)74ITD203(JP.)
..... basis. in fact such adjustment entry is in the nature of 'price of expectancy of interest' and is nothing but a notional entry and cannot be treated as income for the purpose of it act, 1961." after considering the reply and the order of the authorities below, we are of the view that the position of the claim is very clear. the assessee accounted ..... cited above, the ao is directed to allow the claim of the assessee accordingly.42. ground no. 4 in both the appeals is against the enhancement of the income. the income was enhanced by cit(a) in view of the claim of the assessee under s. 36(1)(vii) and deduction under s. 36(1)(viia) was not allowed which were allowed by ..... the ao. therefore, the income of the assessee was enhanced by the cit(a).43. we have already decided ground no. 3 which was in regard to deduction under s. 36(1)(vii), in favour of the assessee. therefore, this .....
Tag this Judgment!Court : Income Tax Appellate Tribunal ITAT Jaipur
Reported in : (1995)55ITD363(JP.)
..... from cit (a)s order under section 263 of the i.t. act, 1961 (the act) setting aside the assessment, as made by the assessing officer (ao) in the case of the assessee for a.y. 1988-89, on the ground of the same being erroneous and prejudicial to the interests of revenue.2. the assessee, an individual, derives his income ..... -1965 requiring the deptt. not to insist too much upon linking or identifying the payments for savings specially with the funds representing assessees income chargeable to tax, as referred to at page 2446 of chaturvedi & pithisarias income-tax act, vol 2, ivth edition was also referred to.4. the ld. d r has not only supported the order under appeal but ..... has further submitted that the order made by the assessing officer was quite sketchy and cryptic and therefore the ld. cit was justified in treating the same as .....
Tag this Judgment!Court : Income Tax Appellate Tribunal ITAT Jaipur
Reported in : (1995)52ITD367(JP.)
..... 3. the central government of india had entered into an agreement with the libyan government for the avoidance of double taxation of income under the income-tax act, 1961 ('the act') and under the corresponding law in force in that country. article 20 of such agreement provided as under :- when a resident of ..... a contracting state derives income which has also suffered tax in the other contracting state, the first mentioned state shall allow a deduction from its tax on the income of that person equal to the tax ..... government of any country outside india- (a) for the granting of relief in respect of income on which have been paid both income-tax under this act and income-tax in that country, or (b) for the avoidance of double taxation of income under this act and under the corresponding law in force in that country, or(c) ** ** **(d) .....
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