Court : Income Tax Appellate Tribunal ITAT Chandigarh
Reported in : (1995)52ITD541(Chd.)
1. this appeal by the revenue relates to assessment year 1982-83. the only effective ground is against the exclusion from the assessee's taxable income of share derived by the assessee from m/s munjal sales corporation, ludhiana and diverted by overriding title to m/s thakur devi investments pvt. ltd. 2. for assessment year 1982-83, the asseessee declared total income of rs. 3,24,634 in her return filed on 28-8-1982. in the computation of total income for assessment year 1982-83, the assessee declared income from m/s munjal sales corporation in which she had share of 8.33 per cent. on 6-2-1982, the assessee gifted 36 per cent of her right, title and interest in munjal sales corporation and its assets including her capital and right to share profits and losses to m/s thakur devi investments pvt. ltd., ludhiana. in effect the component of gift worked out to 3 per cent of the right, title, interest including share of profit and loss in the firm. a copy of the declaration of gift is available at page 2 of the assessee's first compilation. the said gift was accepted by the donee as per copy of the resolution of their board dated 6-2-1982. the other partners of m/s munjal sales corporation had given their consent to the proposed gift in favour of m/s thakur devi investments pvt. ltd. vide their confirmation dated 14-1-1982, a copy of which is available at page 1 of the assessee's first compilation.3. the assessee filed a gift-tax return declaring taxable gift at rs. 33,380. this .....
Tag this Judgment!Court : Income Tax Appellate Tribunal ITAT Chandigarh
Reported in : (2007)112TTJ(Chd.)94
..... madras auto service (p) ltd. 54. .....
Tag this Judgment!Court : Income Tax Appellate Tribunal ITAT Chandigarh
Reported in : (1984)7ITD337(Chd.)
..... the said court followed this judgment subsequently, in the case of cit v.madras wire products [1979] 119 itr 454 (mad.).11. ..... it has been held by the hon'ble madras high court in the case of cit v. .....
Tag this Judgment!Court : Income Tax Appellate Tribunal ITAT Chandigarh
Reported in : (2004)90TTJ(Chd.)754
..... seetharama rao (1976) 105 itr 151 (mad), their lordships of madras high court held as under : "the provisions of section 28(l)(c) of the indiarl income tax act, 1922 can be invoked and the assessee would be liable for penalty only if he was guilty of concealment of income or deliberately furnishing inaccurate ..... surrender of income in the subsequent years was no material to hold that the assessee concealed income in the period under consideration.learned counsel for the assessee in this connection, relied upon the decision of hon'ble madras high court in the case of cit v. .....
Tag this Judgment!Court : Income Tax Appellate Tribunal ITAT Chandigarh
Reported in : (2005)92ITD377(Chd.)
..... the contention on behalf of the revenue that aforementioned decision of the madras high court is inapplicable in the cases of the appellants as the decision was on the basis of the law relating to assessment year 82-83 when there was no exemption in regard to compensation received under vrs, is not well founded. ..... in our considered view, the decision of the madras high court , supra, is squarely applicable to the facts of this case.12. ..... it was contended that the decision of madras high court in the case of cit v. m. ..... it was pointed out that the compensation received by the assessee is liable to tax under section 17(3) being profits in lieu of salary.relying upon the decision of the madras high court in the case of g.n.badami v. ..... 5 lakhs only and that decision of the madras high court in the case of cit v. m. ..... 245 itr 856, the madras high court reiterated its earlier view and held that relief under section 89 was allowable to the assessee in respect of compensation received on voluntary retirement scheme. ..... reference at this stage to the decision of the madras high court in the case of g.n. ..... their lordships of the madras high court have relied upon its earlier decision in the case of cit v. ..... their lordships of the madras high court rejected the claim of the assessee by holding that voluntary retirement/separation amounted to termination of service within the meaning of section 17(3) of the income-tax act, 1961.11. .....
Tag this Judgment!Court : Income Tax Appellate Tribunal ITAT Chandigarh
Reported in : (1984)8ITD396(Chd.)
..... for this proposition he relied on the madras high court judgment in the case of indo-commercial bank ltd. .....
Tag this Judgment!Court : Income Tax Appellate Tribunal ITAT Chandigarh
Reported in : (1984)7ITD811(Chd.)
1. this appeal by the revenue is directed against the order of the aac dated 6-2-1981 relating to the assessment year 1976-77. the grievance of the revenue is that he 'erred in holding that the provisions of section 147(a) is not attracted in this case' and that, 'provisions of section 64(1)(iii) are not applicable in this case and income of minor son is not includible in the income of the assessee'.2. the factual background to be taken into consideration for determination of the issues is as under : for the assessment year 1976-77 which is under appeal before us, the original assessment in the case of shri mela ram, since deceased, was completed on 26-6-1978 on a total income of rs. 39,900 under section 143(1) of the income-tax act, 1961 ('the act'). in the case of smt. sumitra devi, w/o shri mela ram, the assessment for the assessment year 1976-77 was completed on 10-1-1978 on a total income of rs. 47,560. these two assessments were made by the same ito (shri h.k. srivastava) acting as the ito. there was a firm working under the name and style of mangat ram rarnesh kumar, yamunanagar, having business of timber. this firm was constituted of six sons of mela ram, namely, mangat ram, ramesh kumar and surinder kumar who were major and fullfledged partners and vijay kumar, ashok kumar and virinder kumar, minors admitted to the benefits of partnership and bis wife smt. sumitra devi. for the assessment year 1976-77, the assessment of the firm was completed on 27-9-1978 treating .....
Tag this Judgment!Court : Income Tax Appellate Tribunal ITAT Chandigarh
Reported in : (1984)8ITD667(Chd.)
..... name of the transferor transferee area of land k m1. .....
Tag this Judgment!Court : Income Tax Appellate Tribunal ITAT Chandigarh
Reported in : (1992)43ITD348(Chd.)
..... regarding the case of t.khemchand tejoomal (supra) it was submitted that the said decision did not take into consideration the decisions of madras high court in the cases of cit v. ..... on these facts the madras high court held that in view of the finding that the surrender of the guarantee amounts by the assessee was for purposes of avoiding possibly higher losses which would have entailed in the assessee's business in the ..... the facts of the madras high court decision in the case of textool co. .....
Tag this Judgment!Court : Income Tax Appellate Tribunal ITAT Chandigarh
Reported in : (1995)54ITD32(Chd.)
..... it was pointed out that the decisions of the kerala and madras high courts referred to above were duly considered by the tribunal and distinguished. ..... it was submitted that so far as investment allowance was concerned, the requirement of law was that the assessee should be engaged in the production of any article or thing.as regards the madras high court decision in the case of buhari sons (p. ..... ) ltd[l973]9\ itr 289 and of madras high court in the case of cit v. ..... laid down that a hotel was mainly a trading concern and it would not be appropriate in the ordinary sense to refer to the production of food materials in a hotel as manufacture.similarly, it was pointed out that the observations of the madras high court in buhari sons (p. .....
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