Judgment Search Results Home > Cases Phrase: karnataka traffic control act 1960 chapter 5 miscellaneous Court: income tax appellate tribunal itat delhi Page 1 of about 17 results (0.867 seconds)

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

Court : Income Tax Appellate Tribunal ITAT Delhi

Reported in : (1988)25ITD193(Delhi)

..... to the value of exports. he submitted that these licences were saleable and were issued under the import-export policy and not under section 3 of the import and export (control) act, 1947. he submitted that no profit was generated by the assessee. next, he submitted that the right to export was converted into a stock-in-trade (import replenishment ..... of the government and did not flow from any statute. in particular, he pointed out that ccs did not flow from section 3 of the import and export (control) act, 1947. he submitted that whereas the earlier schemes could, be said to have aimed at compensation for certain disadvantages suffered by the exporters the scheme as relevant and ..... the same as that of ie which was in issue in the earlier case of jeewanlal (1929) ltd. v. ito [1981] 130 itr 405 (cal.). (iii) the karnataka high court held in patil vijaykumar v. union of india [19851 20 taxman 363 dissenting from the judgment of the bombay high court in cit v. godavaridevi saraf [1978] 113 .....

Napar Drugs Pvt. Ltd. Vs. Dcit

Court : Income Tax Appellate Tribunal ITAT Delhi

Reported in : (2006)98ITD285(Delhi)

..... mansukhlal nanjibhai patel v. dy. cit 251 itr 341 (guj.); by hon'ble rajasthan high court in man mohan gupta v.acit 274 itr 179 (raj.). hon'ble karnataka high court have in the case of cit v. p.r. metrani (huf) 251 itr 244 (kar.) held that in relation to assessment proceedings it raises a ..... to income-tax assessment proceedings. it is also not correct to say that the assessing officer had required the assessee to produce the shareholders who were not under the control of the assessee company. when the share certificates physically, blank signed forms of transfer, blank cash receipts, sale bills and affidavits etc. duly signed by these ..... genuineness of the shareholding and their confirmations /affidavits had been placed on record the ao himself had initiated enquiry by issuance of summons under section 131 of the it act on all such shareholders. these were duly served and complied with by the shareholders. the shareholders in the enquiry proceedings by the ao had filed affidavits confirming .....

Ece Industries Ltd. Vs. Deputy Commissioner of Income Tax

Court : Income Tax Appellate Tribunal ITAT Delhi

Reported in : (2007)111TTJ(Delhi)11

..... a sale of an undertaking as a going concern and, therefore, it is not a slump sale. learned departmental representative placed reliance on the decision of hon'ble karnataka high court in the case of syndicate bank ltd. v. addl. cit (supra) and on the decision of bombay high court in the case of killick nixon ..... a going concern. on transfer, the assessee transferred the entire undertaking in its working condition as a going concern and the transferee acquired absolute ownership and full control over the running business of the undertaking. (ii) there was no separate sale of building or plant or machinery nor any price was attributable to land, ..... also shows that each undertaking has to be treated as a separate and independent unit. learned counsel also made reference to the provisions contained under section 2(42c) of it act and submitted that undertaking means 'a unit' or 'business activity' but not union of several activities. according to him, 'an undertaking' comprises much more and .....

Reliance International Vs. Income-tax Officer

Court : Income Tax Appellate Tribunal ITAT Delhi

Reported in : (1986)16ITD43(Delhi)

..... that case, to debate as to whether the right to receive cash assistance was a statutory right, having its roots in section 3 of the imports and exports control act or whether it was an equitable right arising from the doctrine of promissory estoppel. it was enforceable right under the law, either way. the following observation of ..... the statutory basis for all these schemes, which were intended to regulate, promote and channelise the country's exports lay in section 3 of imports and exports (control) act. so the same statute as backed up by the schemes of import entitlements and duty drawbacks was behind the scheme of ccs and a legally enforceable right in ..... entitlements and duty drawbacks were given by the government in terms of section 3 of the imports and exports (control) act, 1947, but granting of ccs could not be related to any such statutory provision. it was purely an administrative act, and its authority lay in the circular of the ministry of commerce dated 17-8-1966, referred to .....

Steel Authority of India Ltd. Vs. Deputy Commissioner of

Court : Income Tax Appellate Tribunal ITAT Delhi

Reported in : (1991)38ITD193(Delhi)

..... relating to unabsorbed depreciation, unabsorbed investment allowance, unabsorbed loss and unabsorbed deduction relating to tax holiday. as a consequential amendment, chapter vib of the income-tax act relating to restriction on certain deductions in the case of companies, is proposed to be omitted. these amendments will take effect from 1 st april, 1988 ..... of this company by virtue of clause 6 of public sector iron and steel companies (restructuring) and miscellaneous provisions act, 1978]. the real question in dispute is as to whether clause (b) of first proviso to section 205(1) permits adjustment of such loss/ ..... with proviso to subsection (2); 13. in this case the company has incurred losses in previous financial years falling after the commencement of companies (amendment) act, 1956 (though the company was incorporated with effect from 1973 the losses suffered by the dissolved companies arc deemed to be the losses or unabsorbed depreciation .....

Smt. Krishna Verma Vs. Assistant Commissioner of Income

Court : Income Tax Appellate Tribunal ITAT Delhi

Reported in : (2007)107ITD1(Delhi)

..... p) ltd. to make a distinction between 'error in jurisdiction' and 'error of jurisdiction'. for this a reference has been made to the judgment of the karnataka high court in the case of a. premchand ors.v. iac and ors. where it has been held that the jurisdiction to initiate proceedings for acquisition of immovable ..... , consent cannot give jurisdiction where there is none. in dhirendra nath (supra), the following observations were made in this context (p. 1305): where the court acts without inherent jurisdiction, a party affected cannot by waiver confer jurisdiction on it, which it has not. where such jurisdiction is not wanting, a directory provision can ..... void and incapable of being validated. in dhirendra nath gorai v. sudhir chandra ghosh (supra), the following observations were made in this context: where the court acts without inherent jurisdiction, a party affected cannot by waiver confer jurisdiction on it, which it has not. where such jurisdiction is not wanting, a directory provision .....

Motorola Inc., Erisson Radio Vs. Deputy C.i.T.

Court : Income Tax Appellate Tribunal ITAT Delhi

Reported in : (2005)96TTJ(Delhi)1

..... connection. in this case, the test of predominance of the object of the contract was adverted to. in cit v.energomach exports (232 itr 448), the karnataka high court held that no business connection can be inferred merely because the foreign company deputed its employees in connection with the contract for supply of equipment. the ..... and any notice of reassessment and consequent assessment under section 34 ignoring the return is invalid." here reference can also be made to the full bench decision of the karnataka high court in the case of kareemsons pvt. ltd. v. cit ((1992) 198 itr 543). it provides a good illustration to explain the scheme.their lordships ..... and relied upon by the learned counsel for the revenue. in reaching its conclusion, the delhi bench noted that section 142 was controlled by the words "for the purposes of making an assessment under this act." therefore, for making an assessment and till the time available for making such assessment, the a.o. could issue notice to .....

Shantanu Kumar and Others Vs. Uoi and Others

Court : Income Tax Appellate Tribunal ITAT Delhi

..... in vinod kumar sethi v. state of punjab, air 1982 pandh 372 and a supreme court judgment in state of karnataka v. l. muniswamy, air 1977 sc 1489 in support of his contention that the fir against the petitioners is liable ..... destruction of the property. video clipping played during the course of arguments which showed that a head constable of the traffic police was gheraoed by the protestors and was assaulted, humiliated and obstructed in the discharge of his official duties; his ..... ) the arrestee may be permitted to meet his lawyer during interrogation, though not throughout the interrogation. (11) a police control room should be provided at all district and state headquarters, where information regarding the arrest and the place of custody of ..... elements had indulged in rioting and caused mischief to private and public properties, held rule 7 framed under the bombay police act, 1951 as being arbitrary and observed as under:- "32. ... it is not surprising that the constitution makers conferred .....

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

Court : Income Tax Appellate Tribunal ITAT Delhi

..... is selected. thereafter, functional analysis is carried to identify functions, risk and assets of uncontrolled transactions and comparison is carried with characteristics of the controlled transaction. this is necessary to find whether comparable selected are really comparable and reliable. comparison based on functional analysis include economically significant activities and ..... to 5% adjustment in alp determination. the main reason of dispute lies in divergent interpretations of the proviso to section 92c(2) of the act which contains relevant provisions dealing with such adjustment. in order to resolve the dispute, it may be necessary to make clarificatory amendment in the ..... the revenue's appeal involve issues relating to transfer pricing and pertain to the addition made by way of "adjustments" under section 92ca of the act by determining higher arms' length price than disclosed by the taxpayer in the international transactions carried with its associated enterprises "aes".85. the taxpayer .....

East West Rescue Pvt. Ltd. Vs. Dy. Cit, Spl. Range 14

Court : Income Tax Appellate Tribunal ITAT Delhi

Reported in : (2004)89ITD259(Delhi)

..... court has observed that the tribunal cannot rectify every mistake. according to hon'ble court it can rectify only mistake, apparent from the record.44. the hon'ble karnataka high court has also considered the issue in the case of diamond glass agencies vs. cit (2001) 247 itr 277. in that case the issue related to rectification ..... was dismissed but in second application the tribunal accepted the stand of the assessee that in para 19 of its order, it had relied upon section 310 of companies act, 1956 which had since been amended and had no application to the assessment order under appeal. the tribunal, therefore, recalled its order dated 30th august 1978. ..... shall include services rendered from india but not services rendered in india. shri monga explained that assessee has not claimed deduction u/s. 80-o of the act on the services rendered in india but has claimed deduction on the professional and technical services rendered by it to the foreign concerns from india. another contention of .....