Demag Cranes and Components India (P) Ltd. vs DCIT
Alp: Computation of-Composite Contracts - Sale of Equipment and Commissioning/Installation-A.Y. 2007-08.
The assessee was manufacturing cranes and hoists etc. It also distributed and sold such equipment imported by it. It also under too [LexDoc Id : 441464]
ITAT (Pune)
2012
Bearing Point Business Consulting (P) Ltd. vs DCIT
Business expenses-Prior period expenses-A.Y. 2007-08.
The prior period expenceses were a mix of short provision excess provision or no provision made and pertained to A.Y. 2006-07. Thes [LexDoc Id : 446521]
Global Logic India (P) Ltd. vs DCIT
ALP - Software Development Service-Selecting comparable-A.Y. 2006-07.
The comparables having high ratio of related party transactions could not be selected for ALP purposes.
The net margin of asse [LexDoc Id : 443149]
ITAT (Delhi)
2012
Booz Allen and Hamilton India Ltd. and Co. Kg. vs ADIT
Accrual of income - FTS-Permission from RBI-A.Y. 1998-99.
The assessee a foreign firm had a branch office in India for rendering management and technical services. Certain amount was payab [LexDoc Id : 441369]
Cairn Energy India (P) Ltd. vs DIT
Erroneous order of-Non–application of mind by A.O.-A.Y. 2004-05.
The A.O. allowed assessee's claim of deduction u/s 80-IB(9) without looking into relevant provisions of S. 80-IA(5) r.w.s. 80-IB(13 [LexDoc Id : 437795]
Linklaters and Paines vs ITO
Income deemed to accrue in India - Mistake from record-Solicitors firm's income - Force of attraction rule-A.Y. 1995-96.
The assessee a London based firm of solicitors had no branch office in India. It did some work on Indian projects. The majority of [LexDoc Id : 441371]
Convergys Customer Management vs ADIT and Anr.
Validity of: re-asstt-Failure to File Return-A.Y. 2002-03, 04-05.
A mere non-filing of return could invite action u/s 148 on the ground of escapement of income [Expln. 2 to S. 147] R [LexDoc Id : 437934]
HC (Delhi)
2012
Ajit Singh Rana vs ACIT
Limitation: Initiation of penalty proceedings-Initiation within 4 years-No time for initiation was prescribed.
The initiation within 4 years was not time barred.
Ss. 271BA and 92E of the Income Tax Act, 1961. [LexDoc Id : 458510]
SITEL India (P) Ltd. vs ACIT
Total turnover-Items excluded from export turnover-The items excluded from export–turnover should be excluded from total turnover for computing profits u/s 10A.
S. 10A of the Income Tax Act, 1961 [LexDoc Id : 441515]
ITAT (Mumbai)
2012
Medusind Solutions India (P) Ltd. vs ACIT
Income derived from Unit in FTZ-Interest on FDR pledged as margin money as business income-The assessee was entitled to deduction u/s 10A on interest from FDR pledged as margin money as business income.
The income from interest from NS [LexDoc Id : 441463]
Meinhardt Singapore Pte Ltd. vs ADIT
Validity of: Re-asstt.-Failure to file relevant document-A.Y. 2002-2003, 2003-2004.
The assessee had not field a relevant agreement. This was concealing a relevant fact. The re-opening was valid.
[ [LexDoc Id : 438330]