Search Results For: I. P. Mukerji J


DIT vs. Board Of Control For Cricket In Sri Lanka Through PILCOM

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DATE: September 25, 2018 (Date of pronouncement)
DATE: October 6, 2018 (Date of publication)
AY: -
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CITATION:
S. 5, 9, 163, 166: A representative assessee represents all income of a non-resident accruing or arising in India directly or indirectly from any business connection in India. It is wrong to contend that the representative assessee is not liable for income which has directly arisen or accrued in India. It is also wrong that if the department chooses to make an assessment of the person resident outside India directly, it cannot assess the agent or representative assessee. The Dept has the choice of proceeding against either

In my opinion the Tribunal has made a complete misunderstanding of the law in entertaining the opinion that since the income made by the non- resident Cricket Boards were held to have directly arisen in India, this income could not be deemed to have arisen or accrued to the non-resident in India and the responsibility of the representative assessee was confined to accounting for income which had directly arisen or accrued in India

Asiatic Oxygen Limited vs. DCIT (Calcutta High Court)

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DATE: September 29, 2014 (Date of pronouncement)
DATE: October 5, 2014 (Date of publication)
AY: 2006-200
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CITATION:
The formal reasons given in support of reopening the case cannot be added to or subtracted from or improved in the affidavit-in-opposition

In Hindustan Lever Ltd. Vs. R.B. Wadkar, Assistant Commissioner of Income-Tax And Others (No.1) reported in 268 ITR 322 (Bombay) and Aroni Commercials Ltd. Vs. Deputy Commissioner of Income-Tax And Another reported in (2014) 362 ITR 403(Bom) both Division Bench

Debashis Moulik vs. ACIT (Calcutta High Court)

COURT:
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COUNSEL:
DATE: September 29, 2014 (Date of pronouncement)
DATE: October 5, 2014 (Date of publication)
AY: 2009-10
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CITATION:
“Escapement of income” in s. 147 should be given a strict construction

In my opinion “escapement of income” should be given a strict construction. Not only should it not be used to justify a change of view it should not be used to reopen an assessment on facts, information, documents which were

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