Tag: 274 ITR

AAR : Whether, on the facts and in the circumstances of the case, the proposed loan to be given by Madura Coats (P) Ltd. (MCPL) to Coats Finance Co. Ltd. (CFL) can be considered to be “deemed dividend” under s. 2(22)(e) of the IT Act, 1961, to the extent of “accumulated profits” ?

Authority For Advance Rulings Madura Coats (P) Ltd., In Re Section 2(22)(e) Syed Shah Mohammed Quadri, J., Chairman; K.D. Singh & A.S. Narang, Members AAR No. 645 of 2004 6th April, 2005 Counsel Appeared S.E. Dastur with P.J. Pardiwalla, for the Applicant : R. Jiya Kumar, for the CIT concerned Ruling Syed Shah Mohammed Quadri, J., …

AAR : Whether, when the applicant allots bonus redeemable preference shares to the existing equity shareholders, any income would accrue to the non-resident equity shareholders being the allottees and, therefore, the company is required to deduct tax at source ?

Authority For Advance Rulings Briggs Of Burton (India) (P) Ltd., In Re Syed Shah Mohammed Quadri, J., Chairman; K.D. Singh & A.S. Narang, Members Sections 2(22)(A), 2(22)(B), 194 AAR No. 654 of 2004 4th April, 2005 Counsel Appeared None, for the Applicant : Yashwant Y. Chavan, for the CIT concerned Ruling A.S. Narang, member : In …

AAR : Whether, in the facts and circumstances of the case, interest paid to M/s Rabobank will constitute income in the hands of the non-resident and whether TDS under s. 195 of the IT Act, 1961, is deductible.

Authority For Advance Rulings Jay Shree Tea & Industries Ltd., In Re Sections : 90, 195, 245N(a)(ii), DTAA between India & Singapore, Art. 11 Syed Shah Mohammed Quadri, J., Chairman; K.D. Singh & A.S. Narang, Members AAR No. 646 of 2004 21st February, 2005 Counsel Appeared None, for the Applicant : N.P. Bhagat, for the CIT …

AAR : Whether, on the facts and circumstances of the case, any business profit or income accrues or arises in India in the hands of the applicant out of advertising revenue received/receivable from its agent(s) in India ?

Authority For Advance Rulings Speciality Magazines (P) Ltd., In Re Sections 9(1)(i), 90, DTAA between India & U.K., art. 5, DTAA between India & U.K., art. 7 Syed Shah Mohammed Quadri, J., Chairman & K.D. Singh, Member AAR No. 610 of 2003 7th February, 2005 Counsel Appeared None, for the Applicant : Yashwant Y. Chavan, for …

AAR : The petitioner states that question No. (iii) is reframed by the Authority on its own without there being any request of or consent by the applicant or its authorized counsel

Authority For Advance Rulings Instrumentarium Corporation, In Re AAR (Procedure) Rules, 1996 r. 12, AAR (Procedure) Rules, 1996 R. 19 Syed Shah Mohammed Quadri, J., Chairman & K.D. Singh, Member AAR No. 609 of 2003 2nd February, 2005 Counsel Appeared Rahul Krishna Mitra, for the Applicant : Sanjay Puri, for the CIT concerned Ruling Syed Shah …

Madras H.C : Whether, on the facts and circumstances of the case, the Tribunal was right in confirming the disallowance of gratuity paid to the retiring employees ?

High Court Of Madras Sree Akilandeswari Mills (P) Ltd. vs. DCIT Section 37(1) Asst. Years 1988-89, 1989-90 N.V. Balasubramanian & Mrs. R. Banumathi, JJ. Tax Case (Appeal) Nos. 57 & 58 of 2002 28th January, 2005 Counsel Appeared P.P.S. Janardhana Raja for Subbaraya Iyer, for the Assessee : K. Subramaniam, for the Revenue JUDGMENT N.V. balasubramanian, …

Punjab & Haryana H.C : Whether, on the facts and in the circumstances of the case, the Hon’ble Tribunal was justified in law in deleting the penalty under s. 271(1)(c) amounting to Rs. 73,000 by holding that Expln. 1 to s. 271(1)(c) has not been invoked by the AO ignoring the fact that Expln. 1 to the s. 271(1)(c) is an integral part of the s. 271(1)(c) as held by the Punjab & Haryana High Court in the case of Capital Cinema vs. CIT (1989) 80 CTR (P&H) 131 : (1989) 179 ITR 628 (P&H) ?

High Court Of Punjab & Haryana CIT vs. Prabhu Dayal Lallu Ram Section 271(1)(c), Expln. G.S. Singhvi & Viney Mittal, JJ. IT Appeal No. 35 of 2000 20th January, 2005 Counsel Appeared Rajesh Bindal, for the Appellant : Akshay Bhan, for the Respondent ORDER G.S. Singhvi, J. : In this appeal filed under s. 260A of …
Malcare WordPress Security