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Judgment Search Results Home > Cases Phrase: comparative chart of corresponding sections of 1983 act Court: income tax appellate tribunal itat delhi Page 1 of about 22 results (0.064 seconds)

Mar 21 2006 (TRI)

Deputy Commissioner of Vs. Delhi Press Samachar Patra (P.)

Court : Income Tax Appellate Tribunal ITAT Delhi

Reported in : (2006)101ITD253(Delhi)

..... the comparative chart expenses booked under different units appearing at page 22 of the compilation of the assessee, with a submission that in each and every head, assessee has booked higher expenses in unit no. i because the unit no, i is no longer eligible for deduction under section 80-i of the act. since ..... instant case the impugned assessment satisfied the said tests? from the discovery of secret accounts in the head office, it does not necessarily follow that a corresponding set of secret accounts were maintained in the branch office, though it is probable that such accounts were maintained. but, as the accounts were secret, ..... but no expenses was shown in unit no. iii. in unit no. i another sum of rs. 48,26,988 was shown under the head 'ink', corresponding to that only rs. 1,04,113 was shown under similar head in unit no. iii. he, accordingly, concluded that expenses on ink in unit no. ..... id. dr further pointed out that the assessee has booked the expenses at rs. 17,32,165 under the head 'subscription deposit scheme' but no corresponding expenses are booked in units no.ii and iii nothing has been placed on record on behalf of the assessee either before the cit(a) or ..... has also noticed that other item such as subscription deposit service expenses amounting to rs. 17,32,165 is shown in unit no. i but no corresponding expenses were shown in unit no. iii. with regard to this subscription deposit service expenses, assessing officer observed that the assessee has not brought out a .....

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Jan 31 2008 (TRI)

Nuware India Ltd. Vs. Deputy Commissioner of Income Tax

Court : Income Tax Appellate Tribunal ITAT Delhi

..... order of the cit(appeals), faridabad, passed on 12.09.2005. the corresponding order of assessment was framed by the deputy cit, central circle, faridabad, on 26.2.1999 under the provisions of section 143(3) read with section 148 of the income-tax act, 1961.2. ground no. 1 is residuary in nature, which was ..... year and fixed expenses, like fuel etc. remained more or less the same, leading to trading loss. the assessing officer drew a tabular chart for comparing the results of this year vis-a-vis the results of earlier two years and pointed out that there was a sharp increase in consumption ..... of the nature of differences in the accounts namely, whether the credit balances were more or less or both in the books of the assessee when compared with the confirmed accounts received from those parties. it is also not shown how the sum total of these differences could be said to be the ..... register was not maintained and sales were not verifiable in absence of cash memos. the vouchers of expenses were also filed and the income was ridiculously low compared to a high turnover. the tribunal found as a fact that the claim of the assessee regarding acceptance of the books was not sustainable. this finding ..... was required to furnish the reasons for fall in gross profit. it was explained that the cost of raw-material consumed has gone up by 12% compared with the earlier year due to increase in rate of moulding powder, which was the main raw-material. in this connection, copies of purchase bills were .....

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Mar 06 1997 (TRI)

Narayan Glass Works Vs. Assistant Commissioner of Income

Court : Income Tax Appellate Tribunal ITAT Delhi

..... commission @ 2 per cent on sales of glassware which has been accepted by the revenue. he invited our attention to p. 73 of the paper-book being comparative chart of payment of commission. he also submitted that opinion formed by the cit(a) that provisions of s.40a(3) are violated is formed without affording necessary ..... of semi-automatic presses had been started in the nearby areas. the assessee further submitted that cost of raw material and packing had gone up substantially without corresponding increase in the sale of end product, resulting in fall in margin of gross profit. the assessee supported its submission by giving instances of purchase rate of ..... payable to this party has been allowed by the ao himself, question of liability of rs. 5,473 being non-genuine did not arise. he submitted that acting behind the back of the assessee the ao obtained copy of account of the assessee in the books of madan & co. learned representatives of the parties are ..... disallowance.6. the next grievance is against additions sustained by the learned cit(a) on account of suppressed sales, bogus liabilities and addition under s. 68 of the it act. in turn, the revenue is in appeal against relief allowed by the learned cit(a) as under :---------------------------------------------------------------------- addition sustained relief allowed---------------------------------------------------------------------- rs. rs. rs.----------------------------------------------------------------------(a) suppressed .....

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Aug 29 1997 (TRI)

Eastern Construction Company Vs. Income-tax Officer

Court : Income Tax Appellate Tribunal ITAT Delhi

..... the corresponding contract receipts. the expenditure should be real and if it is incurred for the purpose of business, the same will be clearly allowable under the provisions of it act. (i) the learned counsel also invited our attention towards the chart placed at p. 1 of the paper-book in which the comparative figures ..... of past history. the ao could apply a net profit rate by taking into consideration the past records or the results shown by the other comparable cases of civil contractors. instead of adopting such a method of estimating the assessee's taxable income, the ao has made various ad hoc ..... and where the contract receipts are more than 40 lakhs. however, the presumptive rate of net profit of 8 per cent. incorporated in the aforesaid section represents a just, fair and equitable rate of net profit, which can be taken into consideration for determining the income from contract business in a ..... been given. the details mentioned in the said chart inter alia reveals that the ..... of gross contract receipts, net profit declared by the assessee in asst. yr. 1983-84 to asst. yr. 1985-86 have .....

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Aug 31 2007 (TRI)

Pradeep Agencies-joint Venture Vs. Income Tax Officer

Court : Income Tax Appellate Tribunal ITAT Delhi

Reported in : (2007)111TTJ(Delhi)346

..... the previous year of "every person". it was pointed out by him that the language used in charging section i.e. section 4 is different from the corresponding charging section of it act, 1922 (for short "1922 act"). he examined the provisions of sections 67a, 86 and 167b of 1961 act to consider the taxability or otherwise of income of aop/members of aop. he referred to the definition ..... tax on the aop and its member is different under 1961 act as compared to the provisions of 1922 act. as already discussed, hon'ble supreme court has interpreted the law in this regard by comparing the provisions of sections 3, 2(9) of 1922 act and the provisions of section 2(31) and section 4 of 1961 act. further their lordships have also observed that earlier decision of ..... the case of ito v.ch. atchaiah (supra), the contention of the learned authorised representative that there is no material change in the provisions of 1961 act as compared to similar provisions contained in 1922 act with respect to chargeability of tax relating to aop and its member is liable to be rejected and accordingly rejected. the contention of learned authorised representative that ..... not amount to double taxation as is contended by the assessee.13. he further prepared a chart showing therein the taxable income returned by the constituents of the aop and found that much less tax was paid on the income returned by the constituents as compared to the tax liability of the aop. thus he arrived at a conclusion that it was .....

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Oct 05 2007 (TRI)

Gujarat Guardian Ltd. Vs. Joint Commissioner of Income Tax

Court : Income Tax Appellate Tribunal ITAT Delhi

Reported in : (2008)114TTJ(Delhi)565

..... guidance on cutting of higher thickness glass, etc. (d)the services rendered by guardian are amply borne out from the sample copies of correspondence filed before ao which originate with the receipt of enquiry by the assessee company from guardian salesmen are continued till the time that the goods ..... 12.5 per cent claimed by the assessee? (c) whether the revenue has established justifiability of the disallowance under the provisions of section 40a(2) or section 92 of the act? 15. the evidence on record shows the following. the assessee entered |into an agreement with gge dt. 20th july, 1993. ..... the ao called upon the assessee to furnish details of parties to whom exports were made through the services of intermediaries, complete documentary evidence like correspondence details of sales personnel of the export agent etc. (c) the ao held that the assessee has given a general reply about services rendered ..... assessee even after reducing the export commission during the relevant previous year contributed rs. 34.25 crores towards meeting the fixed cost. the assessee compared to other float glass manufacturers has the highest export sales, as borne out from the statistics for the financial year 1995-96. the assessee ..... export and realisation. the commission paid by the assessee has been allowed as deduction in asst. yrs. 1994-95 and 1995-96. a chart showing fob value of exports, the accrual of commission and payment thereof in different years was also as follows: it was submitted that there .....

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Sep 08 2004 (TRI)

ito Vs. Allied Metal Engg.

Court : Income Tax Appellate Tribunal ITAT Delhi

Reported in : (2005)2SOT81(Delhi)

..... to nepl are directly supplied to century pulp & papers under the same gr number of the transporter whereas corresponding sale bill raised by nepl is for a much higher figure. the comparative figures along with other particulars like bill no. as well as gr no.have been given by the ..... the same consignments at a much higher price to m/s. century pulps and papers and in para 5 of the assessment order bill-wise comparative details have been given in the assessment order, extracted hereinbefore which indicate that assessee has made sales of rs. 11,22,445 to the ..... system for rs. 25.50 lakhs in the relevant previous year. the fabrication of solar system is a much more colour incentive job as compared to other fabrication job undertaken in previous year." the assessee further stated that the orders were received long time back in the year 1994 ..... the firm supplied material for century pulp pipes, the material were dispatched directly to them and documents were exchanged according to sec. 6(2) of the central sales tax act." the assessing officer, however, rejected the explanation of the assessee as factually incorrect with the following observations: "the billing of ..... new addition. the assessing officer has further reproduced in the assessment order the comparative figures of sales and fabrication expenses for the preceding as well as succeeding assessment year as under:- on the basis of the aforesaid chart, the assessing officer noted the percentage of fabrication expenses to the total sales .....

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Apr 11 1989 (TRI)

institute of Marketing Vs. Inspecting Assistant

Court : Income Tax Appellate Tribunal ITAT Delhi

Reported in : (1990)32ITD616(Delhi)

..... institute or any of them. however, none of these engagements shall be for profit.4. before proceeding further the provision of section 11 (4a), which was inserted by the finance act, 1983 w.e.f. 1-4-1984 should be closely noticed and, therefore, reproduced below, because the primary basis of the ..... programme courses, seminars and conference receipts etc.could be said to be business income though there are substantial increase in such receipts, as there are corresponding increase in expenses also.14. the important factor to be noticed is that the surplus only amounted to rs. 3,229 against the receipts of ..... show that it would be highly illogical to treat the case on different footing than the treatment given for the assessment year 1979-80. the comparative figures for this year are as under:- from comparison of the above figures we notice that membership subscriptions have only marginally increased even after 10 ..... molijit singh and miss erajit singh, daughters of dr.jagjit singh for services rendered to the society were also disallowable under the provisions of section 13 of the act.12. the cit(a) in the first appeal vide his order dated 24-3-1988 though agreed with the conclusion arrived at by ..... charitable purpose, viz. relief of the poor, education or medical relief. the assessee institute does not come under any of these three categories. hence section 13(l)(bb) is not applicable at all. alternatively, it is submitted there is no activity of the institute which can be described as of .....

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Oct 28 1985 (TRI)

R.S. Avtar Singh and Co. Vs. Income-tax Officer

Court : Income Tax Appellate Tribunal ITAT Delhi

Reported in : (1985)14ITD366(Delhi)

..... full bench had taken into account the language employed in corresponding statutory provisions for providing relief such as section 45(d) of the wealth-tax act, 1957. after analysing the provisions defining 'industrial company' as contained in the finance act and after taking into account the comparative language of the other provisions, the full bench was ..... learned members could not agree upon the conclusion, the point of difference of opinion as framed by them was referred to the president under section 255(4) of the act, who in turn nominated me as third member to express my opinion in the matter. the point of difference of opinion is : whether ..... , on the facts and in the circumstances of the case, the commissioner of income-tax was justified in passing orders under section 263 of the income-tax act, 1961 holding that assessment orders passed by the ito in respect of assessment years under consideration treating the assessee-firm as industrial undertakings ..... -1983, the decision of the full bench of the tribunal which was rendered on 20-10-1983 was not available. since the full bench decision of the tribunal is now available, this tribunal is bound ..... on the decision of the full bench of the tribunal in the case of ito v.hydle constructions (p.) ltd. [1983] 6 itd 575 (delhi). the learned counsel further contended that when the commissioner passed the orders on 24-6 .....

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Jan 18 2008 (TRI)

Mr. K.K. Khullar Vs. Deputy Commissioner of

Court : Income Tax Appellate Tribunal ITAT Delhi

Reported in : (2008)304ITR295(Delhi)

..... ,71,885/- from malabar steamship co. ltd. and rs. 2,56,815/- from new dholera steamships ltd. these amounts were credited in the books and corresponding debit entries were made in the accounts of the shipping companies. in the year 1947, the assessee floated two private limited companies, called shoorjit vallabhdas ltd. ..... ending on 31.3.1997 to 31.3.2006, (v) comparative details of advance retainership fees received in the financial years ending on 31.3.1998 to 31.3.2005, and (vi) copies of assessment orders passed under section 143(3) of the act for assessment years 2003-04 to 2005-06. it was ..... matter of tax and it is the income which has to be recorded as per system of accounting followed by the assessee in view of section 145 of the act, because the substance of the matter is "income". therefore, there is an infirmity in the order of the learned cit(a) in paragraph ..... high court. the question was whether, for assessment years 1964-65 to 1969-70 the assessee was entitled to exemption from income-tax under section 11 of the act? reversing the decision of the high court, the hon'ble supreme court held that the properties given to the satguru were intended for common ..... to the paper book filed by him, which contained 126 pages.pages 56 to 126 constituted additional evidence consisting of -(i) copies of notices under section 148 of the act issued by the assessing officer for assessment years 1998-99 to 2000-01, (ii) replies submitted by the assessee in compliance to the aforesaid notice .....

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