Search Results Page

Search Results

1 - 10 of 92 (0.83 seconds)
Documents citing R & B Falcon (A) Pty Ltd vs Commissioner Of Income Tax on 6 May, 2008

Jubilant Enpro P. Ltd., Noida vs Acit, Circle- 1, Noida on 16 August, 2018

Ratio laid on by Hon'ble Bombay High Court in case of B.R Bamsi vs. CIT (supra), supports the argument advanced by Ld.AR. We are therefore inclined to consider the plea of assessee by setting aside the issue back to Ld.AO for re-computation of disallowance under section 14A having regards to the decision of Hon'ble Supreme Court in the case of Maxxop investments Ltd vs CIT reported in (2018) 91 taxman.com 154.
Income Tax Appellate Tribunal - Delhi Cites 13 - Cited by 0 - Full Document

Ddit (It)-4(1), Mumbai vs M/S. Linklaters, Mumbai on 11 October, 2023

15. Coming to the another decision relied by the assessee in the case of R&B Falcon Offshore Ltd. v. Addl CIT (supra), the ITAT Delhi bench has dealt with the issue of Article 5(2)(j) of the Indo - US DTAA, wherein the issue was that a Non-resident company which owned a rig arrived in India, due to some repairs to be undertaken before such rig was to be used in India. The issue was whether the period used to repair the rig before installation to be considered for the limitation period of more than 120 days or not, was the issue. It was not the issue whether the placement of the rig in India for which Article 5(2)(j) are applicable or not. Further, the issue dealt by the ITAT Delhi bench relating to Indo - US DTAA whereas the application of Article 5(2)(k) in the case of assessee is Indo - UK DTAA, and it is dealt elaborately in the case of assessee's own case by the Coordinate Bench. Therefore, it is distinguishable to the facts of the present case.
Income Tax Appellate Tribunal - Mumbai Cites 24 - Cited by 0 - Full Document

M/S. Spentex Industries Ltd. vs Commissioner Of C.Excise . on 9 October, 2015

20) It is to be borne in mind that it is the Central Government which has framed the Rules as well as issued the notifications. If the Central Government itself is of the opinion that the rebate is to be allowed on both the forms of excise duties the government is bound thereby and the rule in-question has to interpreted in accord with this understanding of the rule maker itself. Law in this respect is well settled and, therefore, it is not necessary to burden this judgment by quoting from various decisions. Our purpose would be served by referring to one such decision in the case of R & B Falcon (A) Pty Ltd. v. Commissioner of Income Tax1 wherein interpretation given by the Central Board of Direct Taxes (CBDT) to a particular provision was held binding on the tax authorities. The Court explained this principle in the following manner:
Supreme Court - Daily Orders Cites 13 - Cited by 0 - A K Sikri - Full Document

Ddit (E), Delhi vs Petrotech, New Delhi on 11 April, 2017

Even though the CIT(A) has not dealt with the submission of the assessee regarding non- applicability of proviso to section 2(15) of the Act, even in a situation where the activities of the assessee falls in the last limb of section 2(15) of the Act, viz, advancement of any other object of general public utility, the Respondent assessee can support the order of the CIT(A) on grounds not decided by the CIT(A). [Refer : B.R. Bamsi v. CIT (1972) 83 ITR 223 (Bom.)] 9 DDIT ( Exemption) VPetrotech ITA No 6259/ Del/2012 A Y 2009-10 In the end, he vehemently submitted that the assessee is carrying on the activities of the education and Ld. CIT appeal has correctly decided so granted the exemption to the assessee under section 11 and 12 of the income tax act.
Income Tax Appellate Tribunal - Delhi Cites 22 - Cited by 1 - Full Document
1   2 3 4 5 6 7 8 9 10 Next