S. 147 : Reassessment-Reopening of assessment cannot be permitted merely on ground that there is change in view of AO and he subsequently believes that earlier view is incorrect. [S.133(6), 143(3)]
S. 147 : Reassessment-Reopening of assessment cannot be permitted merely on ground that there is change in view of AO and he subsequently believes that earlier view is incorrect. [S.133(6), 143(3)]
S. 147 : Reassessment-After the expiry of four years–Reassessment notice to be seta-side where no income had escaped assessment on account of assessee’s failure to disclose true facts in the assessment. [S. 148, 153A]
S. 143(3) : Assessment-Bogus purchases–Accommodation entries-Readymade garments-Addition of 25% is held to be proper. [S. 69]
S.115JB : Book profits-Provisions for computing book profits
is not applicable to Assessee company, engaged in the business of generation and distribution of electricity, who is required to prepare its books of account under the State Legislation and not as per the provisions of relevant Companies Act, 1956.
S. 50C : Capital gains – Full value of consideration – Stamp Duty Valuation – Where the assessee explained the reasons for fetching a lesser rate on sale of immovable property as compared to the Stamp Duty Valuation, the AO should have remitted the matter to the DVO for determination of the FMV of the immovable property. [S. 45]
S. 40(a)(ia) : Amounts not deductible- Deduction at source-Word ‘payable’ occurring in section 40(a)(ia) not only covers cases where amount is yet to be paid but also those cases where amount has actually been paid.
S. 40(a)(ia) : Amounts not deductible-Deduction at source– Contractor – In absence of express or implicit contract between the assesse and the maistries, payments made to the labourers through maistries / group leaders did not attract deduction at source hence no disallowances can be made. [S. 194C]
S. 40(a)(ia) : Amounts not deductible – Deduction at source – Short deduction – Precedent -Deducted the tax applying the provision of S.194C @2% instead of 194J @ 10%- No disallowances can be made.
[ S.194C, 194J ]
S. 37(1) : Business expenditure- Provision for fall in the value of investment held as stock-in-trade by bank is allowable as a deduction.
S. 37 (1) : Business expenditure-Provision for standard asset being required only to meet the unexpected eventuality is purely contingent in nature and hence is not allowable as a deduction.