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Facts are as under :

'A' sold agriculture land ( situated outside the municipal limits )for Rs. 30 lacs and deposited the total  sale consideration received in cash in his bank account. The sale agreement ie. Ikraarnma was executed for Rs.30 lacs but later on sale deed ( ie registry) was got executed for Rs10 lacs by the buyer.

The date of deposit of cash in the bank account of A correlates with the date of registry i.e. sale deed.

' A ' is having the original copy of sale agreement ie. Ikraarnma in his possession.

The AO of 'A ' made addition in the hands of 'A' for Rs.20 lacs on account of income from undisclosed sources for cash deposited in excess of the registry value despite having taken on record the copy of Ikraanma showing sale consideration of Rs.30 lacs.

Please advice the legal recourse available to A.

'A' sold agriculture land for Rs. 30 lacs and deposited the total  sale consideration received in cash in his bank account. The sale agreement was executed for Rs.30 lacs but later on sale deed was got made for Rs10 lacs by the buyer.

The date of deposit of cash in the bank account of A correlates with the date of registry i.e. sale deed.

' A ' is having the original copy of sale agreement ie. Ikraarnma in his possession.

The AO of 'A ' made addition in the hands of 'A' for Rs.20 lacs on account of income from undisclosed sources despite having taken on record the copy of Ikraanma showing sale consideration of Rs.30 lacs. i.e. AO opted for Sale Deed value.

Please advice the legal recourse available to A.

A manufacturing firm is  situated in area eligible for deduction u/s 80IC and is claiming deduction accordingly. The present constitution of the firm is proprietorship

If the constitution of the firm is changed to partnership, whether it will have any impact on the eligibility of the unit, to claim deduction u/s 80 IC for the balance period.

i.e whether itwill amount to Reconstruction  of firm.

The profits of a private limited company are exempt u/s 80 I A. The company has raised substantial interest bearing loans for investing in new projects of companies under the same management.
The company has given interest free  loans and advances to other group companies for setting up new projects.
The books profits of the company has been reduced considerably because of the interest cost of the said loan raised.
Please advise  :
From Income Tax Point of View :
a)   Implication of  section 14A – If there is JV or no JV
b)   Implications of Section 2 (22) -
None of the shareholder of the lending company is shareholder of the  company to whom loans are given
c)   Implication of Section 115JB
.
From Companies Act / CARO
The provision of section 293  and other applicable sections of the Companies Act
Prejudicial to the interest of shareholders – Though the loans are raised and invested after shareholders' approval,

Query Income  from sale of CER's ;
A company has set up Hydro Power Project and it's profits are eligible for deduction U/s 80 IA.

The provisions of Section 80 IA provides for allowing deduction in respect of profits and gains derived  from the eligible business.

During the course of income tax assessment, Assessing Officer treated the sale of CERs as ancillary profits and  not profits derived from eligible business and hence disallowed deduction U/s 801A.

Our submission :

The  CERs are issued based on  net electricity generated and hence do not fall in the category of  investment linked  incentives OR Profit Linked incentives.

The  origin of CER's are traced to the manufacturing activity and hence it  is a source not beyond the first degree   and are directly linked with the industrial activity ie. Generation of power. 
   
Thus  income from sale of   CER's, being revenue   having direct relation with the business of the company are  taxable as per clause (i) of Section 28 i.e. Income as business income. And hence eligible for deduction U/s 80 IA.

Please advice....