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1 - 10 of 14 (0.22 seconds)The Income Tax Act, 1961
Section 144C in The Income Tax Act, 1961 [Entire Act]
Section 271DA in The Income Tax Act, 1961 [Entire Act]
Section 20 in The Income Tax Act, 1961 [Entire Act]
Section 63 in The Income Tax Act, 1961 [Entire Act]
Section 37 in The Income Tax Act, 1961 [Entire Act]
Section 10 in Income Tax Rules, 1962 [Entire Act]
Reliance Industries Limited, Mumbai vs Acit , Mumbai on 8 March, 2022
Global One India (P.) Ltd. us DCIT (2019) 112 taxmann.com 185 (Delhi-Trib.)
held that Final assessment order passed by Assessing Officer without following directions issued
by Dispute Resolution Panel under section 144C is null and void and hence was to be quashed.
Software Paradigms Infotech (P.) Ltd. v. ACIT (2018) 89 taxmann.com 339 (ITAT Bangalore)
held that Where Assessing Officer/TPO passed impugned final order of assessment under
section 143(3) read with section 92CA without giving effect to or carrying out binding directions
of DRP as required under section144C(10) within time specified under section 144C(13), said
impugned final order was to be set aside
10
ITA 6816/Mum/2024
Royal Canin India Pvt. Ltd
7.2. Respectfully reliance is placed on the order of the Hon'ble Delhi High Court wherein the any
exercise of powers by the AO in contravention of the specific directions of the DRP was held to
be excessive and hence illegal:
Commissioner Of Income-Tax, Andhra ... vs Dhanrajgiri Raja Narasingirji on 7 March, 1973
9. The law mandates only that the payment for services must be at arm's length.
There is no statutory requirement to prove the necessity of such services
respectfully reliance was placed in CIT v. Dhanrajgirji Raja Narasingirji, [1973] 91
ITR 544 (SC)held that Section 37(1) of the Act[Corresponding to section 10(2)(xv)
of the Indian Income-tax Act, 1922] - Business expenditure - Allowability of -
Assessment years 1950-51 and 1951-52 - Whether expenditure incurred by
assessee in connection with criminal litigation for purposes of his business was
deductible under section 10(2)(xv) of 1922 Act as section 10(2)(xv) did not make
distinction between civil and criminal litigation - Held, yes - Whether it is not open
to department to prescribe what expenditure assessee should incur and in what
circumstances he should incur that expenditure.