Judgment Search Results Home > Cases Phrase: unit trust of india act 1963 52 of 1963 chapter i preliminary Court: income tax appellate tribunal itat delhi Page 1 of about 11 results (0.338 seconds)

M/S. L.G. Electronics India Private Limited Vs. the Asstt. Commissione ...

Court : Income Tax Appellate Tribunal ITAT Delhi

..... their products to a wider market, to customers previously familiar only with locally produced goods. the products needed to convince the market that the public could trust that the new packaged product is useful, durable and as good as the locally made one. around 1900, fames walter thompson published a 'house ad ..... the purpose of comparability, i had proposed to use the current year's data (march, 2007) of the comparables.sl. no.company nameampsalesamp/salesremarks1applicomp (india) ltd. relevant data for carrying out amp analysis not available relevant data for2penguln electronics ltd. 3videocon appliances1.631339.30.12accepted4videocon communication ltd. relevant data for carrying ..... with its foreign ae for advertising the brand of the later, which is nothing but an implied transaction. 9.6. he argued that the united nations transfer pricing manual provides for the allocation of such cost of market penetration, marketing expansion and market maintenance strategies between a mne and its .....

Motorola Inc., Erisson Radio Vs. Deputy C.i.T.

Court : Income Tax Appellate Tribunal ITAT Delhi

Reported in : (2005)96TTJ(Delhi)1

..... is discovered in the hardware during the warranty period then "the purchaser shall arrange, at its own cost, the returned shipment of the defective part, sub-assembly or unit (if applicable) to facilitate in new delhi therefor designated by the supplier......". this provision can only be consistent with the position that the property and the risk in ..... that it is an independent entity is reflected from the assessment order for the assessment year 1998-99 wherein it is mentioned that the company has set up a unit in software technology, park at bangalaore and has claimed its income of rs. 91,39,921 as exempt under section 10a of the act. thus, in view ..... this circular, it was contended that even if 10% is assessed as profits arising to the assessee for signing contracts in india, on the basis of the judgment of the madras high court in annamalai's timber trust (supra), the eci having been paid commission of 18%, the assessment would get extinguished.91. before concluding his arguments on .....

Godore Tools (India) (P.) Ltd. Vs. Inspecting Assistant

Court : Income Tax Appellate Tribunal ITAT Delhi

Reported in : (1988)25ITD193(Delhi)

..... cost of production of a certain industry. apparently, the figure which emerged was an average figure on the basis of such information as the various production units submitted to the costing bureau of the govt. of india, ministry of finance. making good the losses is not necessarily the result of the aforesaid method, increasing the margin of profit, however, is. the bose ..... bose malik committee and the p.c. alexander committee to suggest that cash assistance was intended to be given to the various industrial units to enable them to develop their fixed capital infrastructure.35. in 1984, the government of india again appointed a committee on trade policies under the chairmanship of the then commerce secretary sh. abid hussain. this committee presented its .....

Shri Manoj Aggarwal, Bemco Vs. Dcit

Court : Income Tax Appellate Tribunal ITAT Delhi

..... its relevance merely for lack of cross-examination.reference was also made to the supreme court judgments in pooran mal 93 itr 505 @ 526 and surjeet singh chabda v. uoi to contend that the retraction of sunil kapoor two years after his original statement was useless as evidence and cannot be taken advantage of. even on merits of the ..... his case also, there was a search under section 132 on 3.8.2000. he is stated to have sold certain jewellery belonging to several private welfare and marriage trusts to bemco. in his statement on oath before the ddit on 28.8.2000, he stated that the sale was bogus and that they were only accommodation entries without ..... had escaped assessment. reliance was placed on the following decisions in support of this contention: (b) s.p. agarwalla alias sukhdeo prasad agarwalia v. ito 140 itr 1010 (cal.).united electrical co. p. ltd. v. cit and ors.the learned counsel for the assessee has also filed the compilation of the case law.172. mr. kapila, the learned special .....

Napar Drugs Pvt. Ltd. Vs. Dcit

Court : Income Tax Appellate Tribunal ITAT Delhi

Reported in : (2006)98ITD285(Delhi)

..... that may not be entirely binding upon the income tax appellate tribunal.45. there is unanimity in the judgments of high courts and the apex court in india that the decision of one bench of the income-tax appellate tribunal carries no binding force on another bench of equal strength in another appeal on similar issues ..... ground that this question was concluded by the tribunal's previous order in relation to the assessment year 1954-55.33. in the case of surjidevi kunjilal jaipuria charitable trust v. cit 114 itr 685 (all.), the tribunal decided the appeal simply following the earlier decision. hon'ble allahabad high court, therefore, considered it necessary to direct ..... companies were entire distinguishable from the facts of a company where public offer of equity shares is made at large scale and subscriptions are received from all over india.21. the learned dr emphasized that in the order of the hon'ble judicial member it was considered that for arriving at truth of the matter further .....

Dolly Farms and Resort (P) Ltd. Vs. Deputy Commissioner of Income Tax

Court : Income Tax Appellate Tribunal ITAT Delhi

Reported in : (2000)74ITD147(Delhi)

..... been filed. the ao after going through the submissions of the assessee accepted the confirmations from m/s amir chand and m/s boltan india totalling to rs. 3 lacs as these were found to be in order. since no confirmation in respect of other parties had been ..... discovered as a result of search. reliance is also placed by the bombay bench on the case of l. r. gupta vs. union of india (1992) 194 itr 32 (del) as to what is meant by "undisclosed income". it was submitted that in the aforesaid case of sunder ..... found that pp. 101 to 104 of the paper book wherein the copies of statement of account 1995-96 of m/s trikuta leasing (india) (p). ltd. have been furnished along with gir number as mentioned in the same it was submitted that in the letter of confirmation ..... to be discovered as a result of search. reliance is placed by the tribunal on the case of l. r. gupta vs. union of india (1992) 194 itr 32 (del) as to what is meant by undisclosed income. in the aforesaid case of sunder agencies (supra) it .....

Deputy Commissioner of Income Tax Vs. Royal Jordanians Airlines

Court : Income Tax Appellate Tribunal ITAT Delhi

Reported in : (2006)283ITR28(Delhi)

..... the learned cit-departmental representative has relied, in particular, on european convention of state immunity, 1972 and state immunity act of 1978 enacted in the united kingdom. according to the learned cit-departmental representative, section 3 of state immunity act of 1978 clinches the issue, inasmuch as, "a commercial transaction ..... 355: "although at one time the immunity of a foreign state from the jurisdiction of national courts was regarded by some states, particularly the united kingdom and the united states of america, as virtually absolute, certain exceptions whereby a foreign state's interest could lawfully be affected by judicial proceedings were widely acknowledged ..... expressed by the privy council in their judgment reported as cit v. tribune trust (1948) 16 itr 214 (pc).allahabad high court has reiterated the same position in the case of all india defence accounts association and anr. v. union of india and ors. . recently hon'ble supreme court once againkaramchari union v. .....

Bharatiya Janata Party Vs. Deputy Commissioner of Income Tax

Court : Income Tax Appellate Tribunal ITAT Delhi

Reported in : (2002)80ITD89(Delhi)

..... bom) at 622, and approved in anarkali sarabhai's case (supra); (viii) v.s.m.r. jagadishchandran (deed.) v. cit (1997) 227 itr 240 (sc); (ix) east india housing & land development trust ltd. v. cit (1961) 42 itr 49 (sc); (xi) nalinikant ambalal mody v. s.a.l. narayan row. cit (1966) 61 itr 428 (sc); (xiv) industrial credits ..... was treated as a transfer, then those who had invested in the 80l scheme would be placed in a difficult situation as and when they redeem the 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 ..... the parties that the investment in canstar represented a capital asset and the three ingredients stipulated by section 45 stood attracted as per revenue; (iii) any investment in units and other similar schemes entitled an assessee to get a specified minimum stipulated amount after a stipulated period plus something more on the basis of nav; (iv) .....

Shriram Smarak Nidhi Vs. Inspecting Assistant

Court : Income Tax Appellate Tribunal ITAT Delhi

Reported in : (1989)29ITD186(Delhi)

..... shall have the same meaning as in the explanation at the end of clause (b) of sub-section (2) of section 11 ; (iv) investment in units in the unit trust of india established under the unit trust of india act, 1963 (52 of 1963); (v) investment in any security for money created and issued by the central government or a state government; (vi) investment ..... , if a depositee was covered by a particular mode of investment under the relevant provisions of law earlier, the change to a different depositee will not rob the trust of its exemption provided the mode remained the same. he emphasised that the assessee is covered by the proviso to section 13(1)(d) and but for this ..... 1) in clauses (a) and (b) not only deals with the application of income derived from property held under trust for the above purposes but also provide for the accumulation or setting apart for application to such purpose in india of such income. sub-section (2) of section 11, therefore, provides that where 75 per cent of the .....

Hero Honda Motors Ltd. Vs. Joint Commissioner of Income Tax

Court : Income Tax Appellate Tribunal ITAT Delhi

Reported in : (2006)103ITD157(Delhi)

..... was completed was on the basis of the distinction in law between 'setting up of business' and 'commencement of business' as explained in the case of western india vegetable products ltd. (supra). since carrying out of trial production was setting up of business the claim of the assessee was allowed. (iii) that different ..... technical information and any other public (sic), technical or business information shall remain the sole and exclusive property of the licensor and shall be held in trust and confidence for licensor by licensee and that the licensee shall not divulge or communicate information to any other person, that the information obtained will be kept ..... the business commences or, as the case may be, the previous year in which the extension of the industrial undertaking is completed or the new industrial unit commences production or operation.the assessee in the present case has neither incurred the expenditure in question before commencement of his business nor has the expenditure .....