SH Tech Park Developers Pvt. Ltd. Vs The ACIT Circle-22(2) New Delhi
.... expenditure on the construction has not been claimed as deduction. 12. It is most humbly submitted as to what the auditors have stated that as compared to the method of accounting followed by the assessee till the preceding year, there is a decrease in the profit and not that there is dec ...
Income Tax Appellate Tribunal (Delhi G Bench)
Defsys Solutions Pvt Ltd Vs A.C.I.T
.... Court in the case of Kalyan Kumar Ray Vs. CIT 191 ITR 634. The relevant findings of Hon'ble High Court read as under: " 'Assessment’ is one integrated process involving not only the assessment of the total income but also the determination of the tax. The latter is as crucial as the fo ...
Income Tax Appellate Tribunal (Delhi I Bench)
Hitachi Astemo Haryana Private Ltd Vs DCIT
.... nt order is without incorporating of DRP’s directions. As stated above, the reason is that DRP has given certain directions which were to be given effect by the TPO. The AO till passing the final assessment order has not received the order giving effect by the TPO. In this regard, stating that s ...
Income Tax Appellate Tribunal (Delhi I Bench)
Bharat Aluminium Company Ltd Vs Union Of India & Ors
.... run through fabric of section 144B(1) of the Income Tax Act, 1961. Whenever DAO, FDAO is prejudicial to the interest of assessee or RDAO is prejudicial to the interest of assessee in comparison to DAO or FDAO, upon a response to show-cause notice, personal hearing for oral submissions or to pre ...
Delhi High Court
SRF Ltd Vs National Faceless Assessment Centre, Delhi & Anr.
.... June 2021, the objections under section 144(2) of the Act to the draft order dated 05th May 2021, filed on 21st June 2021 were within time. 9. He points out that the Respondent No.1 erred in considering that the Petitioner had opted not to file objections to the draft order dated 05th May, ...
Delhi High Court
Commissioner Of Income Tax, Gujarat Central Vs Saurasthra Cement & Chem. Industries Ltd
.... objections, is empowered to issue such directions as he thinks fit for the guidance of the ITO to complete the assessment. 11. From the reading of Section 153, the period (not exceeding 180 days) commencing from the date on which the ITO forwards the draft order under sub-Section (1) of Se ...
Supreme Court Of India
J.K. Synthetics Ltd. Vs Commissioner of Income Tax
.... o the Inspecting Assistant Commissioner for his guidance. The Inspecting Assistant Commissioner has to consider the draft order and the objections and to give the directions to the Assessing Officer who has to pass an assessment order in conformity with the direction so given. In the present case, t ...
Allahabad High Court
Commissioner of Income Tax Vs Pancham Dass Jain
.... esult as above will not be accepted. This being so, it has to be taken as an admitted fact in this case that the assessee did make purchases genuinely of agricultural implements etc. of the value of Rs. 2,76,352. After giving the aforesaid finding, the Tribunal raised the question as to from whom ...
Allahabad High Court
Commissioner of Income Tax Vs Roadmaster Industries of India (P) Ltd.
.... es his acceptance of the proposed additions/disallowances, even then the ITO is required to complete the assessment on the basis of the draft order. Thus, the draft order is not an order of assessment but an order quantifying the income or loss. The ITO cannot vary the quantum while completing the a ...
High Court Of Punjab And Haryana At Chandigarh
Commissioner of Income Tax Vs Dhanaura Oil Industries
.... f appeal. Further, the Commissioner mentioned ''even otherwise the assessee has not raised any concrete argument nor furnished any material to show how and why the total income computed by the Income Tax Officer is not correct or that the addition made by him is not genuine.'' We are of the view tha ...
Allahabad High Court
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