Court : Income Tax Appellate Tribunal ITAT Chandigarh
Reported in : (2001)78ITD327(Chd.)
..... years, namely, the year in which the lump sum consideration is paid and the five immediately succeeding years. where the know-how is developed in a laboratory, university or institution referred to in sub-section (2b) of section 32a, the consideration shall be spread equally over three years." now in this case, the assessee had ..... is whether the expenditure could be allowed under section 35ab. it was the contention of the ld counsel for the assessee that there being specific section in the act, expenditure incurred should be allowed under section 35ab. for this purpose, it would be relevant to refer to the memorandum explaining the purpose of provisions of ..... law arising from facts which are on record in the assessment proceedings. he, therefore, submitted that expenditure incurred by the assessee is allowable under section 35ab of the act.subsequently the ld counsel for the assessee furnished the page of the judgment of the supreme court in the case of madras auto service (p.) ltd. (supra .....
Tag this Judgment!Court : Income Tax Appellate Tribunal ITAT Chandigarh
Reported in : (2006)100TTJ(Chd.)748
..... in order to make investment in share capital of subsidiary companies, the assessee in the accounting year relevant to asst. yr.1993-94 under question had sufficient funds and surpluses for making investment in the share capital of subsidiary companies even if the borrowed ..... and not under section 143(3) of it act, so, the addition made in asst. yr. 1992-93 does not debar the ao in making addition in asst. yr. 1993-94 in view of the conclusions of the facts ..... arrived at by the ao in asst. yr. 1993-94 under question because ..... 1993-94 involved in the instant ground of appeals by the ao which was never discussed and adjudicated by the ao while framing assessment in asst. yr. 1992-93 because in that assessment year the ao has simply framed the assessment under section 143(1) of it act .....
Tag this Judgment!Court : Income Tax Appellate Tribunal ITAT Chandigarh
Reported in : (2004)90ITD569(Chd.)
..... uttam kaur educational society'. it was submitted that the ao had misinterpreted the provision of law governing the trust. as per article 4 of the trust, donation to university, school or other like institutions is one of the objects of the trust and 'education' stands covered under this article. the ao had deliberately omitted the word ..... recipient society, which was primarily in the field of education. however, it was found as under:- a) the recipient society was set up on 21.7.1993 for promoting charities in the field of education. b) the recipient society was confined to the pages of the trust deed and accounting records without any charitable activity ..... purposes when no income was utilised for achieving the objectives of the trust. further the requirement for claiming exemption under section 11(1) of the i.t. act, is not fulfilled. 3. i) the learned cit(a) has misdirected herself in admitting the additional evidence without affording any opportunity to the assessing officer as .....
Tag this Judgment!Court : Income Tax Appellate Tribunal ITAT Chandigarh
Reported in : (2004)87TTJ(Chd.)1
..... income of the assessee.the assessing officer further observed that yield of rice bran, phuck, etc. shown was low in comparison to yield fixed by the punjab agriculture university. the assessing officer accordingly held that a sum of rs. 35,000 would be considered in making the estimate' of the income of the assessee.the assessing officer ..... the order of the commissioner (appeals) in case of m/s ganesh rice mills dated 15-6-1994 cannot be interpreted as acceptance of his action as a universal proposition of law. the learned departmental representative therefore submitted that order had been passed on misconception and even otherwise the revenue is not barred from differentiating the same.with ..... set off to the extent of rs. 33,87,550 against addition made under section 68/69a of the act) was set aside back to the file of commissioner (appeals).(vii) the directions in order dated 22-6-1993 were in connection with the trading addition of rs. 42,11,331 as the assessee had submitted that these .....
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