IBS Software Services Private Limited Vs Union Of India Represented By The Secretary
.... s received from the DRP within one month from the end of the month in which such directions is received." 25. In view of the aforesaid discussion, we have no hesitation in holding that the assessment order dated 31st August 2023 passed by FAO two years after the DRP directions, is time ...
High Court Of Kerala
Ares Diversified Vs ACIT Central Intl. Taxation 1 (1)(1), New Delhi
.... ment dated 28.10.2022) on 01.11.2022 for the objections filed on 28.10.2022, 5 days after the due date for filing of objections before the Panel i.e., 23.10.2022. The AO has reported that no final assessment has been ordered till the date. The AO as per the provisions of the IT Act, should have ...
Income Tax Appellate Tribunal (Delhi D Bench)
Nikon India Private Ltd. Vs ACIT
.... The role of NFAC is not that of an AO but it only act as a co-ordinating agency. The NFAC exercises some powers and functions of the AO concurrently in a limited manner to merely facilitate the conduct of faceless assessment proceedings contemplated under Section 144B of the Act. In the absence ...
Income Tax Appellate Tribunal (Delhi I Bench)
Commissioner Of Income Tax - International Taxation -1 Vs Augustus Capital Pte. Ltd.
.... In our view, this submission is misconceived because Explanations 6 and 7 alone would have no meaning if they were not read along with Explanation 5. Therefore, if Explanations 6 and 7 have to be read along with Explanation 5, which concededly operates from 01.04.1962, they would have to be cons ...
Delhi High Court
Egis International S.A. Vs ACIT
.... t same rate of tax as the Appellant and there was no profit shifting motive. b. These AOPs are incorporated as per mandate of the Govt's Projects and have been assessed to meet the arm's length standard by the Le TPO for same assessment year, 17 The Ld AO/ Ld TPO/ Ld CIT(A) grossly er ...
Income Tax Appellate Tribunal (Delhi I Bench)
DCIT Vs BJN Holdings Ltd
.... ng officer assumed jurisdiction to make an assessment in pursuance of the notice under Section 143(2). The notice was issued in the name of the amalgamating company in spite of the fact that on 2 April 2013, the amalgamated company MSIL had addressed a communication to the assessing officer inti ...
Income Tax Appellate Tribunal (Delhi A Bench)
Delhi Cargo Service Center Vs ACIT
.... 015-16 and thus cannot be allowed. Liability for interest being in the nature of penalty, the Ld. AO made the impugned disallowance under section 37(1) of the Act. 6. The Ld. AR submitted that the liability for interest incurred by the assessee is compensatory in nature and thus is admissib ...
Income Tax Appellate Tribunal (Delhi B Bench)
FIL India Business & Research Services P. Ltd Vs DC
.... ount of Rs.1,71,351/- be disallowed and the balance addition be deleted. 6. Learned DR on the other hand supported the order of lower authorities and objected to the additional evidences filed but however stated that if the additional evidences are admitted, the same be sent back to lower a ...
Income Tax Appellate Tribunal (Delhi B Bench)
MD Everywhere India (P) Limited Vs DCIT
.... ted is concerned, we find the Ld. CIT(A) rejected the contention of assessee by observing as under : “(iii) R System International Limited: (a) The above mentioned company has been rejected by the TPO on the ground that the financial year of the company did not end in March. While the ...
Income Tax Appellate Tribunal (Delhi I-1 Bench)
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
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