Court : Income Tax Appellate Tribunal ITAT Kolkata
Reported in : (2008)115TTJ(Kol.)577
..... passing the above quantitative filters, the review was based on the selecting companies providing software development services.qualitative selection (companies involved in manufacturing, trading or any other activities not akin to consultancy services were rejected) this resulted in the selection of 12 companies. subsequently all loss making companies ..... before proceeding to discuss the determination of alp on transaction by transaction basis, shri mitra submitted that as per section- 92c(1) of the it act. the arm's length price of an international transaction is required to be determined using any of the prescribed methods, being the most appropriate ..... and further step down subsidiaries incorporated in foreign countries, all the which are admittedly "associated, enterprises" (ae), within the meaning of section 92a of the it act. the said aes are as follows (a) development consultants international limited (dcil), a company incorporated in bahamas; (b) the kuljian corporation (tks), a .....
Tag this Judgment!Court : Income Tax Appellate Tribunal ITAT Kolkata
Reported in : (1993)45ITD22(Kol.)
..... . it was submitted that the cases referred to related to different issues. reference was made to the decision of the supreme court in the case of union of india v.paras laminates pvt. ltd. [1990] 186 itr 722 to contend that the president had the inherent power to constitute a special bench, ..... in particular, shall disclose the following information in respect of the period covered by the account -- ... (xi) (a) the amount of income from investments, distinguishing between trade investments and other investments. (b) other income by way of interest, specifying the nature of the income. (c) the amount of income-tax deducted if the gross ..... 80j 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 april 1, 1988, and .....
Tag this Judgment!Court : Income Tax Appellate Tribunal ITAT Kolkata
Reported in : (1983)6ITD225(Kol.)
..... difficulty and, therefore, he disallowed the claim.28. the assessee went in appeal before the commissioner (appeals) and the commissioner (appeals) following the decision in cit v. union bank of india ltd. [1976] 102 itr 270 (bom.) allowed development rebate on additions of safe deposit lockers and safe. he also allowed development rebate on the addition ..... central land mortgage bank ltd. v. cit [1968] 67 itr 89 (sc). the bank has earned dividend in course of its normal business. money is stock-in-trade of the assessee and the surplus money was invested in shares. under these circumstances, the collection charge paid by the assessee, if any, was deductible as business expenditure of ..... by a common order. the assessment for the assessment year 1972-73 was completed on 25-7-1974. a notice under section 148 of the income-tax act, 1961 ('the act') was issued upon the assessee on 7-3-1977 indicating that the ito had reason to believe, in consequence of information in his possession, that income .....
Tag this Judgment!Court : Income Tax Appellate Tribunal ITAT Kolkata
Reported in : (1982)1ITD160(Kol.)
..... exercising its legislative function by resort to the doctrine of promissory estoppel. their lordships also went on to observe that if the u.p. sales tax act did not contain a provision enabling the government to grant exemption, it would not be possible to enforce the representation against the government, because the ..... preexisting relationship between the parties or not. it is not necessary, in order to attract the applicability of the doctrine of promissory estoppel, that the promisee, acting in reliance on the promise, should suffer any detriment. what is necessary is only that the promisee should have altered his position : the alteration of position ..... the exercise of a sovereign or governmental function and a trading or business activity of the government, so far as the doctrine of promissory estoppel is concerned.21. their lordships of the supreme court in arriving at the above conclusion have followed the following decisions :union of india v. anglo-afghan agencies air 1968 sc 718 .....
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