S. 264 : Commissioner-Revision of other orders–Filed after expiry period of limitation- justified in dismissing the petition. [S. 143(3), 147]
S. 264 : Commissioner-Revision of other orders–Filed after expiry period of limitation- justified in dismissing the petition. [S. 143(3), 147]
S. 147 : Reassessment-After the expiry of four years-Interest income – Accrual- No failure to disclose material facts–Reassessment is bad in law. [ S. 5, 148]
S. 148 : Reassessment–Merged with another company-Notice issued in name of assessee became invalid and quashed [S. 147].
S. 68 : Cash credits- Trade creditors- Deletion of addition is held to be justified on facts. [S. 260A]
S. 45 : Capital gains- Business income- Short term capital gains- Taken delivery of shares and used own funds–Assessable as capital gains and not as business income. [S. 28 (i)]
S. 40(a)(ia) : Amounts not deductible-Deduction at source Usance interest-Letter of credit discount charges-Merely in nature of reimbursement of cost incurred by suppliers under agreed arrangements and not interest- Not liable to deduct tax at source. [S. 2(28A, 194A]
S. 40(a)(ia) : Amounts not deductible – Deduction at source – Reimbursement of expenses – Federation of International Hockey for arranging for provisional services connected with event of Hockey World Cup–Not liable to deduct tax at source. [S. 9(1)(i), 195]
S. 37(1) : Business expenditure-Consultancy services – Foreign travelling expenditure of representative – Allowable as business expenditure.
S. 69 : Income from undisclosed sources—Bogus purchases- Purchases were not part of sales shown by the assessee- Bogus purchase for suppressing the profits of the business- Addition is held to be justified.
S. 68 : Cash credits—Unsecured loans-Explanation was not satisfactory – Addition is held to be justified.