Court : Income Tax Appellate Tribunal ITAT Delhi
Reported in : (1983)5ITD440(Delhi)
..... the maintenance and control of class i and kaiser-i-hind forests, waste land, water channels and drinking places in the hill patties of the kumaon division; construction, repair and maintenance of such small irrigation projects of such classes or types thereof as may be specified by the state government by general or special order in ..... wells, tanks and ponds for the supply of water for drinking purposes, washing and bathing purposes and regulation of sources of water supply for drinking, regulating the construction of a new building or the extension or alteration of any existing building, assisting the development of agriculture, commerce and industry, the administration of civil and criminal ..... ) delegate to such committee power, with such conditions as they may think proper to impose, to frame any scheme binding on each gaon sabha as to the construction and maintenance of any joint work and as to the power which may be exercised by any such sabha in relation to such scheme; and (b) frame .....
Tag this Judgment!Court : Income Tax Appellate Tribunal ITAT Delhi
Reported in : (1983)6ITD575(Delhi)
..... gardens and all sorts of contracts for procurement and supply for local, municipal, state, central authorities, government departments, railways, universities or for any other person, firms or companies. 2. to undertake the construction of every description and to erect, rebuild, enlarge, alter, pull down, improve, re-model existing works and ..... smaller stone pieces, cement is processed to manufacture concrete slabs and certain other movable parts are first manufactured before they are utilised in the construction work. all these activities independently are eligible for being treated as manufacturing or processing of goods and would, thus, get covered under the ..... its memorandum of association: "a. the main objects to be pursued by the company on its incorporation are: 1. to carry on the business of contractors for construction of roads, buildings, houses, flats, factories, office, dams, canals, tanks, reservoirs, cyphons, bridges, hydel projects, power houses, tunnels, culverts, drains, .....
Tag this Judgment!Court : Income Tax Appellate Tribunal ITAT Delhi
Reported in : (1985)13ITD478(Delhi)
..... and sale of the multi-storeyed buildings. in that event, what would happen to the vested interests of the flat owners from whose moneys it was constructed in the first instance as i see, impossible situations are created for the department from such legal fictions besides bewildering nightmares for the assessees concerned. i ..... of relationship existing between the assessee-company and the flat owners. the assessee owned three plots of land on which the multi-storeyed buildings were to be constructed for residential purposes. it invited persons who may wish to procure such flats for such purposes as units of self-contained accommodation in the proposed multi- ..... is the owner of multi-storeyed buildings in which these various flats have come into being under different contracts with different persons for the purpose of constructing residential or commercial units for them.the learned first appellate authority also held that in relation to the contention of the assessee put forth before him .....
Tag this Judgment!Court : Income Tax Appellate Tribunal ITAT Delhi
Reported in : (1986)16ITD43(Delhi)
..... the company from the unemployment grants committee also periodically. the said instalments of grants were always credited to revenue in the accounts of the company. during the period when construction was going on and instalments were received, there was no trading done by the company. (b) on the above facts, the question for determination was whether the ..... or to enable the assessee to run its business more economically, as in the case of siddhartha publications (p.) ltd. (supra) and (iii) towards meeting the cost of construction of one's capital works, as in the case of seaham harbour dock co. (supra). in the case of a non-trading receipt, its mode of utilization by the ..... revenue account would become relevant and it is here that the finding of the court of appeals becomes relevant, namely, that the grant was to meet the cost of construction and, hence, of capital nature. on either reasoning, the receipt was not taxable in that case. what is the position in the present case the receipt is .....
Tag this Judgment!Court : Income Tax Appellate Tribunal ITAT Delhi
Reported in : (1988)25ITD193(Delhi)
..... 8 of the impugned order that that cost could take two forms : viz.(1) to incur capital expenditure so as to improve the infrastructural facilities such as construction of godown and warehouse in the vicinity of their foreign market and (2) to incur extra expenditure on advertisement publicity, etc., for the promotion of the ..... a promotion nature...." similarly to neutralise the disadvantages of freight differential formation of indigenous shipping companies was encouraged and shipping corpn. of india was incorporated. railways also provided concessional tariff for carrying goods from the manufacturing centre to the port of loading.alexander committee devoted a full chapter to consider tariff system.to ..... o.b. value was as below : (a) drawback (also indicate whether all industry rate or branch rate). (e) any fiscal relief available on exports, such as railway freight concession, etc, if so, indicate the amount per unit of production. net f.o.b. cost. (10) shortfall as a percentage of net f.o.b. .....
Tag this Judgment!Court : Income Tax Appellate Tribunal ITAT Delhi
Reported in : (1993)46ITD312(Delhi)
..... company". by making a reference to the cbdt circular no. 103 dated 17-2-1973, their lordships observed as under: we are of the opinion that the construction placed by the cbdt upon the definition represents the correct view. adopting the view contended for by the department would result in anomalous and inequitable results. take the case ..... 1966, an "industrial company' means a company which is mainly engaged in the business of generation or distribution of electricity or any other form of power or in the construction of ships or in the manufacture or processing of goods or in mining. according to the explanation to clause (d) of sub-section (7) of section 2, ..... : (c) 'industrial company' means a company which is mainly engaged in the business of generation or distribution of electricity or any other form of power in the construction of ships or in the manufacture or processing of goods or in mining. explanation: for the purposes of this clause, a company shall be deemed to be mainly engaged .....
Tag this Judgment!Court : Income Tax Appellate Tribunal ITAT Delhi
Reported in : (1996)56ITD232(Delhi)
..... in respect of the capital gains derived from the sale of assets other than residential house property is available subject to investment being made on the purchase or construction of a residential house property and subject to the condition that he is or does not within specified period become owner of another residential house property, the ..... section shall apply where the assessee owns on the date of the transfer of the original asset, or purchases within the period of one year after such date or constructs, within the period of three years after such date, any residential house, the income from which is chargeable under the head 'income from house property', other ..... of one year before or two years after the date on which the transfer took place purchased or has within ,a period of three years after that date constructed a residential house (hereafter in this section referred to as the new asset), the capital gain shall be dealt with in accordance with the following provisions of this .....
Tag this Judgment!Court : Income Tax Appellate Tribunal ITAT Delhi
Reported in : (1997)62ITD185(Delhi)
..... the rule of equity that a person should not suffer if he was prevented by 'sufficient cause' for making a compliance. no doubt the word 'sufficient' should receive a liberal construction so as to advance substantial justice, but as observed by the hon'ble supreme court in the case of sarpanch, lonand grampanchayat (supra), the discretion is to be exercised to .....
Tag this Judgment!Court : Income Tax Appellate Tribunal ITAT Delhi
Reported in : (2002)83ITD577(Delhi)
..... made, the liability of the appellant for payment of tax does not get crystallised. on these submissions the learned counsel of the assessee placed reliance on the decisions in sequoia construction co, ltd. v.p.p. sun, ito (1985) 158 itr 496 (del); detecon indian project office v. ito (1994) 210 itr 260 (del); in case of mitsui & co. (it appeal .....
Tag this Judgment!Court : Income Tax Appellate Tribunal ITAT Delhi
Reported in : (2002)80ITD89(Delhi)
..... canstar units on maturity, etc. in concluding his arguments, the learned counsel referred to the special bench decision of the tribunal in the case of , highlighting the doctrine of purposive construction further contending that when two views were possible in respect of an issue, which had not been conclusively settled by the hon'ble supreme court, then the view in favour ..... are a guide to us in the present appeal, are as follows : "the words and expressions defined in one statute as judicially interpreted do not afford a guide to the construction of the same words or expressions in another statute unless both the statutes are pari materia legislations or it is specifically provided in one statute to give the same meaning .....
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