Search Results For: Rajpal Yadav (JM)


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DATE: October 14, 2014 (Date of pronouncement)
DATE: October 15, 2014 (Date of publication)
AY: 2005-06 & 2006-07
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Expenditure by way of royalty for use of technology cannot be disallowed on the ground of being capital in nature or for non-business purpose

The arrangement between the assessee and the Australian company has been duly signed by both the parties. The rate per piece has also been specified therein. The royalty has been paid in actual. MACNAUGHT is not a related concern of …

Groz Engineering Tools Pvt. Ltd vs. DCIT (ITAT Delhi) Read More »

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DATE: September 26, 2014 (Date of pronouncement)
DATE: October 4, 2014 (Date of publication)
AY: block period
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There is a perceptional difference in the operative force of section 271(1)(c) vis-à-vis section 158BFA(2). The charge against the assessee u/s 158BFA(2) could be, why they failed to compute true disclosed income out of the seized material.

On a comparative study of the scheme of assessment of undisclosed income for the purpose of block period, penalty impossible u/s 271(1)(i)(c) and penalty impossible on the undisclosed income in the block period, we find that income for the block …

Mohd. Khasim vs. ACIT (ITAT Bangalore) Read More »

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DATE: March 11, 2014 (Date of pronouncement)
DATE: March 19, 2014 (Date of publication)
AY: 2008-09
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CITATION:
ITAT hauls up AO & DRP for “blatantly frivolous & unsustainable” additions. Suggests that accountability mechanism be set up to put a check on AO. Rationale for existence of ineffective DRP questioned


ITAT hauls up AO & DRP for “blatantly frivolous & unsustainable” additions. Suggests that accountability mechanism be set up to put a check on AO. Rationale for existence of ineffective DRP questioned

if an action of the AO is so blatantly unreasonable that such seasoned senior officers well versed with functioning of judicial forums, as the learned DRs are, cannot even go through the convincing motions of defending the same before us, such unreasonable conduct of the AO deserves to be scrutinized seriously. At a time when evolving societal pressures demand greater degree of accountability in the governance also, it does no good to the judicial institutions to watch such situations as helpless spectators. If it is indeed a case of frivolous addition, someone should be accountable for the resultant undue hardship to the taxpayer