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Grasim Industries Ltd., Mumbai vs Dcit Range 6(3), Mumbai on 13 June, 2023

25.2 After hearing both the sides, we find the AO has only allocated the expenses but no income was allocated. We find the co-ordinate Bench of the Tribunal in the case of M/s. Procter & Gamble India Ltd. Vs. DCIT, vide ITA No. 5466/Mum/99 order dated 27th November, 2006 for the A.Y. 1990-91 has held that head office expense allocated to the units are not to be taken into consideration for computing the income of the assessee eligible for deduction u/s. 801 and also u/s 8OHH.
Income Tax Appellate Tribunal - Mumbai Cites 62 - Cited by 4 - Full Document

M/S. Grasim Industries Ltd., Mumbai vs Dcit Cit Cir. 6(3), Mumbai on 23 June, 2023

25.2 After hearing both the sides, we find the AO has only allocated the expenses but no income was allocated. We find the co-ordinate Bench of the Tribunal in the case of M/s. Procter & Gamble India Ltd. Vs. DCIT, vide ITA No. 5466/Mum/99 order dated 27th November, 2006 for the A.Y. 1990-91 has held that head office expense allocated to the units are not to be taken into consideration for computing the income of the assessee eligible for deduction u/s. 801 and also u/s 8OHH.
Income Tax Appellate Tribunal - Mumbai Cites 56 - Cited by 1 - Full Document

Deputy Commissioner Of Income ... vs M/S. Siemens, Mumbai on 5 March, 2025

10. In view of the above factual aspects and case laws of Hon'ble Delhi High Court in the case of Leroy Somer & Controls (India) (P.) Ltd. (supra), we are of the view that the assessee has sufficiently complied with the requirement of Rule 10D(i) of the Rules and moreover the AO has not raised any specific issue which specific documents is not produced under section 92D(3), hence, we conclude that the assessee has furnished all the informations as asked for by the AO and unless and until a specific defect is pointed out in the submissions of documents, penalty under section 271G of the Act cannot be levied. We delete the penalty and allow the appeal of the assessee."
Income Tax Appellate Tribunal - Mumbai Cites 16 - Cited by 0 - Full Document
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