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This is a case where reassessment is sought to be made over change of opinion about the manner and computation of deduction under Section 80-IA, which is not permissible.
Sun-n-Sand Hotels Private Limited Vs Additional/Joint/ Deputy Assistant Commissioner of Income Tax/Income Tax Officer, National Faceless Assessment Centre
(2022) TaxCorp(LJ) 28804 (HC-BOMBAY) · Section 80-IA
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In any event, the time to issue notice may have been extended but that would not amount to amending the provisions of Section 151 of the Act.
J M Financial and Investment Consultancy Services Private Limited Vs Assistant Commissioner of Income Tax
(2022) TaxCorp(LJ) 28793 (HC-BOMBAY) · Section 151
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JAO to consider all submissions made by the Assessee and grant a personal hearing with at least seven days advance notice.
Bharat Capital And Holdings Limited Vs Income Tax Oficer
(2022) TaxCorp(LJ) 28734 (HC-BOMBAY)
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Notices issued after Apr 01, 2021 are unsustainable and bad in law even if one was to apply the impugned Explanations to the Notifications, since they do not cover Section 147 (as amended) which empowers the Revenue reopen an assessment subject to Sections 148 to 153, which includes Section 148A.
Tata Communications Transformation Services Limited Vs Assistant Commissioner of Income Tax 14(1)
(2022) TaxCorp(LJ) 28723 (HC-BOMBAY)
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Since the proposed reopening was issued after the expiry of four years, Revenue has to show that there was fault on Assessee’s part to truly and fully disclose material facts required for assessment.
Hanwant Manbir Singh Vs Deputy Commisioner of Income Tax
(2022) TaxCorp(LJ) 28706 (HC-BOMBAY)
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Not being parties to the appeals, they were not competent to make the applications for transfer. In such circumstances the applications for transfer of appeals were invalid and on such invalid applications no order for transfer of appeals could have been passed.
MSPL Limited Vs Principal Commissioner of Income Tax-1
(2022) TaxCorp(LJ) 28651 (HC-BOMBAY)
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Remuneration and interest from partnership firm cannot be treated as gross receipt.
Perizad Zorabian Irani Vs Principal Commisioner of Income-Tax
(2022) TaxCorp(LJ) 28640 (HC-BOMBAY) · Section 44AB
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Assesse is directed to maintain USD 10 Mn under an Escrow account to meet any tax requirements likely to result from a Master Merger Agreement.
Business Process Outsourcing, LLC Vs The Authority For Advance Rulings
(2022) TaxCorp(LJ) 28580 (HC-BOMBAY)
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Show cause notice dated 25th March 2010 as well as order dated 10th December 2013 have to be quashed and set aside.
INGRAM MICRO INC. VERSUS THE INCOME TAX OFFICER, (INTERNATIONAL TAXATION) – TDS – 3, THE UNION OF INDIA THROUGH THE SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, NEW DELHI
(2022) TaxCorp(LJ) 28567 (HC-BOMBAY) · https://taxcorp.in/FileOpenDT.aspx?ID=86735&Category=Judgment&CategoryType=Zip
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Under Section 195, the payer is responsible for deduction of tax at source and as such no liability under Section 195 could be fastened on the Assessee, who was only a guarantor of the share purchase transaction.
Ingram Micro Inc. Vs The Income Tax Officer
(2022) TaxCorp(LJ) 28556 (HC-BOMBAY)
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Change in opinion cannot constitute reason to believe.
Mangalore Refinery and Petrochemicals Limited Vs The Deputy Commissioner of Income Tax
(2022) TaxCorp(LJ) 28519 (HC-BOMBAY)
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The assessment order is required to be quashed and set aside.
Hactom Agro Pvt Ltd Vs National E Asesment Centre & ors
(2022) TaxCorp(LJ) 28518 (HC-BOMBAY)
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The notice for personal hearing should be given at least 7 days in advance.
Tata AIG General Insurance Company Ltd Vs Ad /Joint/Deputy/Asistant Commisioner of Income Tax/Income Tax Oficer & Ors.
(2022) TaxCorp(LJ) 28502 (HC-BOMBAY)
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Since Assessee placed the list of rural branches along with supporting documents, it was Revenue's duty to examine the classification as per Explanation (ia) to Section 36(1)(viia).
HDFC Bank Ltd. Vs Assistant Commissioner of Income-tax-2(3)
(2022) TaxCorp(LJ) 28493 (HC-BOMBAY) · Section 148
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In the present case, there is no qualm over the fact that the Assessee had entered into a contract with ONGC on turn-key basis for enhancing the exploration/production capacity of the platform.
Larsen & Toubro Ltd. Vs Deputy Income-tax (International Taxation) 4(1)
(2022) TaxCorp(LJ) 28492 (HC-BOMBAY) · Section 44BB
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The payments made by the petitioner to the non-resident assessess in the execution of the contract with ONGC is properly assessable under the provisions on Section 44BB of the Act, 1961.
LARSEN & TOUBRO LIMITED, VERSUS GIRISH DAVE, DIRECTOR OF INCOME-TAX (INTERNATIONAL TAXATION) , BOMBAY, VINAY SINHA, DEPUTY INCOME-TAX (INTERNATIONAL TAXATION) 4 (1) MUMBAI AND UNION OF INDIA
(2022) TaxCorp(LJ) 28485 (HC-BOMBAY) · https://taxcorp.in/FileOpenDT.aspx?ID=86665&Category=Judgment&CategoryType=Zip
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Project for which permission was subsequently granted was different from the one for which IOD was obtained earlier, therefore no substantial question of law arose in the case.
Abode Builders Vs Commissioner of Income Tax
(2022) TaxCorp(LJ) 28464 (HC-BOMBAY) · Section 80-IB(10)
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CBDT has not extended the time-limit for passing any order under Section 144C(13) of the Act vide Notification No.74/2021 dated 25th June 2021, and hence, there is no extension of time-limit to 30th September 2021 to pass the order under Section 144C(13).
SHELL INDIA MARKETS PRIVATE LIMITED VERSUS ADDITIONAL/JOINT/DEPUTY/ASSISTANT COMMISSIONER OF INCOME TAX/INCOME TAX OFFICER
(2022) TaxCorp(LJ) 28454 (HC-BOMBAY) · https://taxcorp.in/FileOpenDT.aspx?ID=86641&Category=Judgment&CategoryType=Zip
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The Assessing Officer was duty bound to provide all the documents called for by petitioner and his reluctance to provide these documents only would make the court draw adverse inference against respondent.
Tata Capital Financial Services Limited Vs Asistant Commisioner of Income Tax
(2022) TaxCorp(LJ) 28451 (HC-BOMBAY)
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The order impugned in this petition is quashed and set aside.
TATA CAPITAL FINANCIAL SERVICES LIMITED VERSUS ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 1 (3) (1) AND ORS.
(2022) TaxCorp(LJ) 28446 (HC-BOMBAY) · https://taxcorp.in/FileOpenDT.aspx?ID=86633&Category=Judgment&CategoryType=Zip
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