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Judgment Search Results Home > Cases Phrase: sashastra seema bal act 2007 section 147 computation of period of sentence Sorted by: recent Court: income tax appellate tribunal itat Page 2 of about 11 results (0.272 seconds)

Apr 30 2008 (TRI)

Acit Vs. Goldmine Shares and Finance Pvt.

Court : Income Tax Appellate Tribunal ITAT Ahmedabad

Reported in : (2008)113ITD209(Ahd.)

..... during the assessment year 1966-67, the assessee commenced another activity, viz., manufacture of alloy steels. both the activities fell within the fifth schedule to the act. the assessee sustained a loss in the manufacture of alloy steel, whereas profits were earned from the manufacture of automobile spares. the assessee claimed relief under section ..... initial assessment year or in subsequent assessment year.42. the fourth sub-head for our consideration is that the provision overrides all other provisions of the act only for computing profit and gains of the eligible business for the determining the quantum of deduction under the section. this restricts the application of ..... be admissible to all small-scale industrial undertakings even if they are engaged in the production of articles listed in the eleventh schedule to the income-tax act. in the case of other industrial undertakings, however, the deduction will be available, as at present, where the undertakings are engaged i the production .....

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Apr 08 2008 (TRI)

Styler India (P) Ltd. Vs. Joint Commissioner of Income Tax

Court : Income Tax Appellate Tribunal ITAT Pune

Reported in : (2008)113ITD55(Pune.)

..... , lay out of the vehicles, components, parts, bodies". there are other clauses providing for acting as consultants and advisers. at p. 2 of the paper book, there is detail of the various activities handled by managing director mr. van den oever during ..... i proceed to examine the facts and circumstances of this case. in the memorandum of association of the assessee company, one of the main objects is to act as "consultant, adviser and provide technical service for the development/manufacture of new products, modification in methods/systems of manufacture, assembly, fabrication and in the design ..... and discussion with different persons to locate the prospective clients. o that there was no evidence that the appellant had even received any proposal or offer to act as a consultant or advisor to provide technical services during the previous year. o that case law cited by the assessee viz. neil automation technology ltd. .....

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Feb 08 2008 (TRI)

Jammu and Kashmir Bank Ltd. Vs. Assistant Commissioner of Income

Court : Income Tax Appellate Tribunal ITAT Amritsar

Reported in : (2008)114TTJ(Asr.)728

..... be followed. reliance is placed on the following judgments: (i) the judgment of hon'ble delhi high court in the case of director of it (exemption) v. lovely bal shiksha parishad (supra). (ii) the judgment of hon'ble supreme court in the case of radhasoami satsang v. cit (supra). (iii) the judgment of hon'ble punjab ..... facility. however, in order to attract further investment to this sector, an urgent need has been felt for providing more tax incentives to investors. 17.2 the act, therefore, provides tax exemption to such infrastructure capital funds and companies which are established for the purposes of mobilising resources for financing infrastructure facilities. 17.3 accordingly, ..... for this proposition, he relied on the following judgments: (i) the judgment of hon'ble delhi high court in the case of director of it (exemption) v. lovely bal shiksha parishad ; (ii) the judgment of hon'ble supreme court in the case of radhasoami satsang v. cit , (iii) the judgment of hon'ble punjab & haryana .....

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Jan 25 2008 (TRI)

Arvind Bhartiya Vidhyalya Samiti Vs. Assistant Commissioner of Income

Court : Income Tax Appellate Tribunal ITAT Jaipur

Reported in : (2008)115TTJ(JP.)351

..... so saying, the appellate authority referred to the balance sheet. the appellate authority further noticed that the assessee samiti was a registered samiti under the rajasthan societies act and that it was also recognised by the cbse. he observed that if there was any misutilisation or mismanagement, action could be taken against the members ..... an educational institution solely existing for education and not for the purpose of profit and therefore, was entitled to exemption under section 10(22) of the act.adverting to the various allegations made by the ao in the assessment order, the learned authorised representative further submitted that the other allegations of the ao ..... dec, 1999. the case was selected for scrutiny.during the assessment proceedings, the ao noticed that the appellant was not having registration under section 12aa of the act nor any exemption under section 10(23c)(vi) was available. when asked, the appellant responded vide letter dt. 27th dec, 2005, mainly stating that the .....

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Jan 25 2008 (TRI)

Dcit, Spl. Range-i Vs. Jindal Photo Films Ltd.

Court : Income Tax Appellate Tribunal ITAT Delhi

..... cit v. balkrishna malhotra 81 itr 759, the supreme court held that the interpretation of a provision in a taxing statute rendered years back and accepted and acted upon by the department should not be easily departed from. the following observations at page 762 of the judgment are important: interpretation of a provision in a ..... that the machineries purchased by the appellant relating to manufacturing of color roll films where machineries covered by the provision of eleventh schedule of the i.t. act. however, after detailed discussion i have held that the appellant is not entitled to investment allowance during the current year and appellant shall be free to claim ..... would be the photo films while adjudicating upon the exemption available under the section, we cannot deal with each and every entry in schedule xi of the act by sitting down to decide what to our minds is fulfilling the priority needs in various vital fields like medicine, communication and education. till the entry stands .....

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Jan 18 2008 (TRI)

Genesis Overseas (P) Ltd. Vs. Deputy Commissioner of Income Tax

Court : Income Tax Appellate Tribunal ITAT Delhi

Reported in : (2008)116TTJ(Delhi)385

..... (del) wherein the following question has been referred to the full bench for decision: whether satisfaction of the officer initiating the proceedings under section 271 of the it act can be said to have been recorded even in cases where satisfaction is not recorded in specific terms but is otherwise discernible from the order passed by the ..... out by the order of the assessing authority. the requisite satisfaction thus is to be arrived at by the ao in the course of any proceedings under the act which would mean assessment proceedings and the satisfaction as envisaged by the hon'ble delhi high court in the case of ram commercial enterprises ltd. (supra) ..... the assessee has been into this business for many years. accordingly, the commission expenses of rs. 8,30,630 are disallowed under section 40a(2) of the it act, 1961.6. according to the learned departmental representative, the aforesaid observations/findings recorded by the ao in the assessment order were sufficient to show that the assessee .....

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Nov 30 2007 (TRI)

Ntpc Ltd. Employees Provident Vs. Income Tax Officer

Court : Income Tax Appellate Tribunal ITAT Delhi

Reported in : (2008)113TTJ(Delhi)285

..... of prosecution proceedings when the artificial veil was lifted to identity the individuals who had to be prosecuted. apart from the above, section 2(31) of the it act defines 'persons'. in the said definition individuals and aops etc. are distinctly and categorically mentioned as separate entities. in the light of the above i am of ..... trust is to be treated as individual because the trust is represented on behalf of the employees and trustees being individual, provision contained under section 194a of the it act will not be attracted, the learned counsel placed reliance on the decisions in the cases of ito v. arihant trust and ors.; ganesh chhababhai vaalabhai patel ..... the authorities is not justified because in various cases categorical findings have been recorded about the status of the trust in relation to section 194a of the it act, we have already reproduced the relevant observations made in these judgments by the hon'ble courts and on going through the same, there appears to be .....

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Nov 02 2007 (TRI)

Kisan Discretionary Family Trust Vs. Assistant Commissioner of Income

Court : Income Tax Appellate Tribunal ITAT Ahmedabad

Reported in : (2008)113TTJ(Ahd.)918

..... circular no. 2 of 2002 dt. 15th feb., 2002 issued by the central board of direct taxes ('cbdt for short) under section 119 of the it act, 1961 (the act' hereinafter).the criticism of the said circular is enumerated at paras 30 to 33, with the latter enlisting the infirmities as found therein. prior to that, ..... making assessments likely to result into demands and in effecting their recovery, they are lethargic and indifferent in granting refunds and giving reliefs due to assessees under the act. dilatoriness or indifference in dealing with refund claims (either under section 48 or due to appellate, revisional, etc. orders) must be completely avoided so that ..... assessee did not appeal against the assessment for block period because assessed undisclosed income was 'nil', but thereafter, moved an application under section 154 of the act dt. 23rd march, 2005 stating therein that the assessee's system of accounting being cash system and the ao having mentioned the system as mercantile system without .....

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Oct 26 2007 (TRI)

Rolls Royce Plc Vs. Dy. Director of Income-tax

Court : Income Tax Appellate Tribunal ITAT Delhi

Reported in : (2008)113TTJ(Delhi)446

..... arising directly or indirectly through or from any business connection in india, can be taxed in india. the expression 'business connection' was earlier not defined in the act. the finance act, 2003 w.e.f. 1st april, 2004 i.e. as applicable to asstt. year 2004-05 and onwards has inserted two new explanations to clause (i) ..... reach a final conclusion regarding the exact quantum of income that has escaped assessment or even a final conclusion regarding chargeability of such income to tax under the act. a prima facie formation of an opinion would suffice. the fact that contracts were executed in india could reasonably lead to conclusion that income has accrued in ..... the facts and circumstances of the case, the ao was of the view that the appellant was having a business connection in india under section 9 of the act as well as permanent establishment under article 5 of the double taxation avoidance agreement (in short 'dtaa') between india and uk. the business connection and permanent .....

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Oct 26 2007 (TRI)

Rolls Royce Plc Vs. Dy Director of Income Tax

Court : Income Tax Appellate Tribunal ITAT Delhi

..... directly or indirectly through or from any business connection in india, can be taxed in india. the expression 'business connection' was earlier not defined in the act. the finance act, 2003 with effect from 1st april, 2004 i.e. as applicable to assessment year 2004-05 and onwards has inserted two new explanations to clause (i ..... ) of section 9(1) clarifying that expression 'business connection' will include a person acting on behalf of non-resident and who carried on certain activities.however, for the purpose of our present discussion, the amended provisions have no relevance as the ..... activities which convert the requests for quotation into orders. (v) the managing director of rril mr. tim jones had issued a certificate under foreign corrupt practices act which certifies that in respect of agreement with air force, there is no permission to offer, promise or give any pecuniary or other advantage directly or indirectly. .....

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