Paramount Communication Pvt. Ltd. Vs DCIT
.... authorities including CIT(A). Thus, non-consideration of the new facet of contentions raised before the CIT(A) does not appear justified. 7.2 Hence, without going into merits of the correctness of additions made by the Assessing Officer, we consider it expedient to restore the matter back t ...
Income Tax Appellate Tribunal (Delhi I Bench)
Pr. Commissioner Of Income Tax (Central) -1 Vs M/S Forum Sales Pvt. Ltd
.... vised return under sub-section (4) or sub-section (5) [or an updated return under sub-section (8A)] of that section, or (b) fails to comply with all the terms of a notice issued under sub-section (1) of Section 142 or fails to comply with a direction issued under sub-section (2-A) of that s ...
Delhi High Court
M/S. Spicejet Limited Vs Deputy Commissioner Of Income Tax
.... )(1) are as under: i. Supplemental Rent /Maintenance Reserve of Rs.26,88,07,231/- ii. Engine Guarantee Availability Fee of Rs.5,24,155/- iii. Repair of Rotables of Rs.3,75,556/- iv. Logo Printing of Rs.25,15,000/- 39. As far as supplemental rent/maintenance reserve is ...
Income Tax Appellate Tribunal (Delhi D Bench)
Ball Beverage Packaging (India) Pvt. Ltd. Vs ACIT
.... as been divided in two categories, i.e. one is Revenue and the other is Capex. "Checking remarks for section 43A" were also mentioned in this chart. AO noticed that out of total 20 entries, 17 entries were categorized in Revenue and 12 entries were categorized in Capex. AO noticed that ...
Income Tax Appellate Tribunal (Delhi A Bench)
Spice Jet Limited Vs Addl. CIT
.... s per Article 5 of the relevant. According to him, m leasing of an aircraft which is located in India ought not to result in an existence of PE and there is also such allegation made by the lower authorities in the present case. It is his submission that the definition of royalty under the Incom ...
Income Tax Appellate Tribunal (Delhi D Bench)
Baker Hughes Energy Technologies UK Ltd Vs ACIT
.... vy Industries (2020) 7 SCC 347, Para 26 and 31 at pgs. 159 & 162 of attached compilation held mere existence of a project office does not give rise to a PE in India unless it is shown that the project office was engaged in carrying out actual business activities. No such evidence has been le ...
Income Tax Appellate Tribunal (Delhi D Bench)
ACIT Vs Elentee India Pvt. Ltd.
.... ceptable to AO. AO noted that majority of the expense were incurred in cash and assessee had not controverted the fact that the guest house expenses was not used for the stay and residence of the Directors. He therefore disallowed 50% of the guest house expenses amounting to Rs.18,11,088/-. ...
Income Tax Appellate Tribunal (Delhi B Bench)
ACIT Vs Idemitsu Lube India P. Ltd.
.... opy of the decision. He, therefore, submitted in view of the settled law, no interference to the order of CIT(A) is called for. 16. We have heard the rival submissions and perused the material available on record. The issue in the present ground is with respect to the addition of Rs.6,31,0 ...
Income Tax Appellate Tribunal (Delhi C Bench)
M/S. Pacific Crest Pte. Ltd. Vs DCIT
.... (a) the amount paid or payable (whether in or out of India) to the assessee or to any person on his behalf on account of the provision of services, and facilities in connection with, or supply of plant and machinery on hire used, or to be used, in the prospecting for, or extraction or produc ...
Income Tax Appellate Tribunal (Delhi D Bench)
M/S. Cameron (Singapore) Pte. Ltd Vs Deputy Commissioner Of Income Tax
.... rom head office in Singapore without the involvement of the project office and further the make available condition under section 12(4)(b) of India – Singapore DTAA is not satisfied, however, before us, learned counsel appearing for the assessee has made an alternative claim by pleading that the ...
Income Tax Appellate Tribunal (Delhi D Bench)
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