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Commissioner Of Income Tax-Xvii vs Idea Cellular Ltd. on 19 February, 2010

It was not explained how the same payment in earlier year is commission and subsequent year it is discount. Further we are unable to agree with the submission of the learned counsel for the assessee that no income has been accrued to the assessee at the time of purchase of recharge coupons. Under 12 ITA Nos.1560 & 1561/Mds2011 very similar set of facts the Hon'ble Delhi High Court has considered the issue in the case of CIT v. Idea Cellular Ltd.
Delhi High Court Cites 27 - Cited by 37 - A K Sikri - Full Document

Panipat Woollen And General Mills Co. ... vs Commissioner Of Income-Tax on 20 January, 1970

(h) The assessee company has also argued that from this Assessment Year onwards, they have changed their accounting system and. not deducting tax as per section 194H. Now, it is a settled law and accounting entries in the books of account of assessee cannot alter the legal position nor can override the statutory provisions as held by Hon'ble Supreme Court in the cases reported Commissioner of lncome-tax Vs Panipet Woollen & General Mills Co. Limited [103 ITR 66(SC)] and Sutlej Coton Mills Limited Vs Commissioner of Income-tax [116 ITR l(SC)]. As long as the law is not changed, the same procedure as per law but not as per books of account is to be followed by assesee company.
Punjab-Haryana High Court Cites 15 - Cited by 7 - Full Document

Delhi Milk Scheme vs Commissioner Of Income-Tax And Deputy ... on 4 March, 2008

In this context, I rely on Delhi Milk Scheme Vs ITO 300 ITR 373(Del.) where the consideration was paid to its agents for selling milk through booths and claimed it as "discounted sale", but Hon'ble High Court of Delhi has held it to be "commission" as defined in section 194H relying on explanation 1 of section 194H. It is quite usual for assessees to claim the amount as "discount" and not as "commission", even though it is commission only to come out of section 194H of the LT. Act.
Delhi High Court Cites 5 - Cited by 9 - M B Lokur - Full Document
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