Search Results Page

Search Results

1 - 5 of 5 (0.47 seconds)
Documents citing Goutham Constructions, Anantapur vs Department Of Income Tax on 5 November, 2013

M/S. Spr Spirits Private Limited ... vs Deputy Commissioner Of Income Tax, ... on 28 February, 2024

The contention that the validity of the transactions cannot be looked into within the frame of the question is, with respect, of the mark because merely legal validity does not necessarily give a touch of genuineness to the transaction, which depends on various other considerations. Therefore, the further contention that since the question referred to the Special Bench is limited to the application of the rule laid down in McDowell & Co. Ltd.'s case (supra), it presupposes that the sale and lease-back transaction is valid and therefore it cannot be held to be non-genuine, ITA Nos.130/Bang/2023 M/s. SPR Spirits Pvt. Ltd., Bangalore ITA No.653/Bang/2023 Nadakrishna Thimmaiah, Bangalore Page 34 of 41 cannot be accepted. Every step in the whole transaction may be legally correct, but still whether the whole transaction is genuine in the sense that it is not a subterfuge or colourable device or a dubious method is an entirely different question not dependent solely on the fact that every step in the transaction is legally valid or correct."
Income Tax Appellate Tribunal - Bangalore Cites 38 - Cited by 0 - Full Document

Income Tax Officer, Koramangala ... vs Nadakrishna Thimmaiah, Bangalore on 28 February, 2024

The contention that the validity of the transactions cannot be looked into within the frame of the question is, with respect, of the mark because merely legal validity does not necessarily give a touch of genuineness to the transaction, which depends on various other considerations. Therefore, the further contention that since the question referred to the Special Bench is limited to the application of the rule laid down in McDowell & Co. Ltd.'s case (supra), it presupposes that the sale and lease-back transaction is valid and therefore it cannot be held to be non-genuine, ITA Nos.130/Bang/2023 M/s. SPR Spirits Pvt. Ltd., Bangalore ITA No.653/Bang/2023 Nadakrishna Thimmaiah, Bangalore Page 34 of 41 cannot be accepted. Every step in the whole transaction may be legally correct, but still whether the whole transaction is genuine in the sense that it is not a subterfuge or colourable device or a dubious method is an entirely different question not dependent solely on the fact that every step in the transaction is legally valid or correct."
Income Tax Appellate Tribunal - Bangalore Cites 38 - Cited by 0 - Full Document
1