De Golyer And Macnaughton Corp. Vs ACIT
.... e has contended that the stay of employees of the appellant in India was less than the threshold of 90 days as provided under the India-US DTAA for creation of Service PE. It was submitted that the Assessing Officer has based his order on the finding that the contract deliverables were for a per ...
Income Tax Appellate Tribunal (Delhi D Bench)
ACIT Vs Ashish Gupta
.... 14A read with Rule 8D can be made. 10. The assessee has claimed expenses of Rs. 80,415/- on securities transaction tax, in the total expenses of Rs.21,04,632/-, which relates to earning of Capital Gains on Shares and is not related to business income. The terms of Seventh proviso to secti ...
Income Tax Appellate Tribunal (Delhi A Bench)
Anshu Gupta Vs ITO
.... see has also challenged the validity of the order passed by the CIT(A). 3. Our record show that this appeal was listed for hearing on 16.12.2021 and thereafter on each date of hearing none appeared on behalf of the assessee inspite of several notices. 4. on 18.01.2024 the bench pointe ...
Income Tax Appellate Tribunal (Delhi A Bench)
AM Infrastructure Private Limited Vs ACIT
.... pellate authority we find that the assessee did not comply with the notices issued by the CIT(A). The assessee has also not responded to the notices of the AO who was forced to pass an exparte order. 4. Before us also the assessee has chosen not to attend. However, in the interest of justi ...
Income Tax Appellate Tribunal (Delhi A Bench)
Transnational Growth Fund Ltd Vs ITO
.... ondonation of delay and are satisfied with the cause of delay. Hence, the delay is condoned. 4. Coming to the facts of the case there is no denial that NFAC has dismissed the appeal in limine though there is a reference of service of notice through e-mail but the appeal has been dismissed i ...
Income Tax Appellate Tribunal (Delhi H Bench)
Yuva Jagriti Evam Jan Kalyan Mission Trust Vs CIT (Exemption)
.... , a communication of the notice must be in terms of the provisions as enumerated. The provisions do not mention of communication to be 'presumed by placing notice on the e-portal. A pragmatic view has to be adopted always in these circumstances. An individual or a Company is not expected to keep ...
Income Tax Appellate Tribunal (Delhi H Bench)
DCIT Vs Adventure Resorts And Cruises Pvt. Ltd.
.... . The notices u/s 133(6) of the Act were received back with the report ‘no such person in existence at the given address.’ The ld. AO also found certain ambiguities and discrepancies in the invoices and, thus, concluded that it was a case of fake purchases. The ld.CIT(A), however, has taken into ...
Income Tax Appellate Tribunal (Delhi A Bench)
Ahluwalia Contracts India Ltd Vs ACIT
.... ok. The deposit was, thereafter, made but delayed by 11 hours and Ld. AR says that the same was due to technical glitch in the software or internet connectivity. The ld. AR has relied certain judgements mentioned below to submit that if the delay is on technical reasons, the deposit has to be co ...
Income Tax Appellate Tribunal (Delhi A Bench)
HCL Technologies Malaysia SDN BHD (Formerly Known As HCL Axon Malaysia SDN BHD) Vs ACIT
.... In view of the above, we find the allegation leveled by the ld. AO in his order that services were rendered by assessee to HCLT is in direct contravention to the findings recorded by the ld. DRP. Needless to mention that the observations of the ld. DRP are binding on the ld. AO as per section 1 ...
Income Tax Appellate Tribunal (Delhi A Bench)
Rabinder Taranjeet Singh Keer Vs ACIT
.... stained the addition in part for which the assessee is in appeal before us raising the following grounds:- “1. On the basis of facts and the circumstances of the ’case and as per law, the delay in filing of appeal please be condoned as husband of the appellant was under treatment as he was ...
Income Tax Appellate Tribunal (Delhi F Bench)
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