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Assistant Commissioner Of Income Tax, ... vs South Eastern Coalfields Limited, ... on 30 October, 2023 cites

Pr. Commissioner Of Income Tax Central 2 vs M/S Ushdev International Ltd. on 26 July, 2019

201/BIL/2012,401/BIL/2014,115/BIL/2015,102,103,162/BIL/2017, 204/RPR/2017, 169/RPR/2018, 33/RPR/2019 204/BIL/2012, 382/BIL/2014, 103/BIL/2015, 98,99/BIL/2017, 188/RPR/2017, 171/RPR/2018, 54/RPR/2019 assessment proceedings u/s.143(3) of the Act. It was also the submissions of the Ld. AR that the assessee's duty does not extend beyond true and full disclosure of primary facts. It is for the A.O to decide what inference or facts can be reasonably drawn and what legal inference have ultimately to be drawn. On this aspect, reliance was placed Kolkata Discount Company Ltd. (supra) and CIT Vs. Usha International Ltd.
Supreme Court - Daily Orders Cites 0 - Cited by 33 - Full Document

The Commissioner Of Income Tax vs M/S Sociedade De Fomento Industrial ... on 25 January, 2022

- copy placed as Attachment S3 • PCIT v Hindusthan Aeronautics Ltd (2022) 143 taxmann.com 357 (Karnataka), - copy placed as Attachment S4 • CIT v Sociedade De Fomento Industrial (P) Ltd (2020) 429 ITR 358 (Bombay), - copy placed as Attachment S5 • H T Media Ltd v PCIT (2017) 399 ITR 576 (Delhi), - copy placed as Attachment S6 • CIT v Gujarat Apollo Industries Ltd (2015) 55 taxmann.com 158 (Gujarat), - copy placed as Attachment S7 • Maxopp Investment Ltd v CIT (2018) 402 ITR 640 (SC) (para 41 ),
Supreme Court - Daily Orders Cites 3 - Cited by 12 - Full Document

Commissioner Of Income Tax Ii vs M/S Modipon Ltd. on 24 November, 2017

In the case of Commissioner of Income Tax Vs. Modipon Ltd. (2011) 334 ITR 102 (Delhi) wherein it has held that "had this expense were booked in earlier year, the assessee would have paid lower taxes. In any case, there is no loss of revenue". 7.24 In reply, ld CIT DR supported the orders of lower authorities. 7.25 We have considered the rival submissions. Considering the settled position of law and totality of the facts to allow any expenditure which pertains to a year earlier to the relevant assessment year, in that case in order to compute the true profit and gains of the year so as to ascertain the taxable income and tax liability, it has to be seen that whether such 73 South Eastern Coal Fields Ltd.
Supreme Court - Daily Orders Cites 12 - Cited by 29 - R Gogoi - Full Document

M/S Goodyear India Ltd. vs Commissioner Of Income Tax, Delhi on 16 October, 2019

Reverting to the facts of the present case, the assessee has stated that they have employed ESM companies and have made payment to them and has also deducted TDS and its necessary deposit to the Government account has been completed. The onus is on the assesse to prove these statements. The Hon'ble Supreme Court of India in the case of LaxminarayanMadanLalVs. CIT (SC) 86 ITR 439 has held that mere existence of agreement between the assessee and its agent does not prove the genuineness of the transactions in a particular case. It all depends on facts and circumstances of each case and the Revenue Authorities is bound to look into the genuineness of the transaction in each of the case. The Hon'ble Delhi High Court in the case of Goodyear India Ltd. vs Commissioner of Income-Tax reported as 246 ITR 116 has held that even if there is an audit report filed by the assessee that does not prevent the Assessing Officer to ask for relevant documentary evidences and details from the assessee to check the genuineness of the transaction and the entire conduct of the assessee.
Supreme Court - Daily Orders Cites 0 - Cited by 7 - Full Document

Western Coalfields Ltd. vs State Of Maharashtra on 6 May, 2016

14.4 We have considered the rival submissions and perused the material evidence placed on record. We have also perused the order of the ld. CIT(A), wherein the ld CIT(A) has upheld disallowance made by the AO under the head land crop compensation relying on the order of the ITAT Nagpur Bench of the Tribunal in ITA No.18-22/Nag/2001, which according to the assessee was not on the similar facts and thus, nowhere covers the issue with respect to the expenses paid for land crop compensation incurred by the assessee. The order passed by the ITAT Nagpur Bench of the Tribunal is dated 28.02.2002. However, subsequently in ITA No.475/Nag/2007, vide order dated 10.08.2009 in the case of assessee's sister concern has deleted the disallowance/addition made under the head crop compensation. Since the expenditure incurred and disallowed on account of land crop compensation is on the basis of facts and was dealt with by the Nagpur Tribunal in assessee's own case and in the case of M/s. Western Coalfields Ltd. (supra) i.e. sister concern of the assessee in different manner, which suggests that the facts under these two appeals were on different footings and therefore, the facts in the present case needs to be examined whether those are similar with the nature and 159 South Eastern Coal Fields Ltd.
Supreme Court - Daily Orders Cites 2 - Cited by 1 - Full Document
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