proviso to section 2(15) and section 13(8) are
inapplicable and the appellant is a genuine charitable
organization. Consequently, exemption under section ... disallowance under section 43B cannot be
made in the process of computing the total income under
section 11 to 13 including under section
proviso to section 2(15) and section 13(8) are
inapplicable and the appellant is a genuine charitable
organization. Consequently, exemption under section ... disallowance under section 43B cannot be
made in the process of computing the total income under
section 11 to 13 including under section
company the provisions of
IT(TP)A Nos.355, 2127/Bang/2016
Page 9 of 21
Sec.115JB of the Act were applicable ... with
provisions of Sec.210 of the Companies Act. Explanation below Sec.115JB
of the Act provides that for the purposes of section 115JB
accepted the disallowance made y the company
u/s 14A of the Act amounting to Rs.355,6660/-.
4. Subsequently, the AO initiated rectification proceedings ... given any basis for the suo-moto
disallowance of Rs.355,660/- u/s 14 A of the Act . In other words, the
conclusion
Price Received Rs. 91,63,07,355/-
Short fall being adjustment u/s. 92CA Rs. 9,29,05,354/-
34. As already stated, during
Supreme Court held that Section
36(1)(va) and Section 43B(b) operate on totally different
equilibriums and have different parameters for due dates ... record" occurs in section 154 . It also finds place in
section 254(2) . The purpose behind enactment of section
254(2) is based
u/s. 158BC r.w.s
143(3) dated. 30.04.2003 is modified as under:
Rs. Rs.
INCOME AS PER ORDER
DATED 09.12.2005 44,355 ... Court
of Karnataka 60,000,000
----------------
104,355,612"
----------------
5. Thereafter the AO issued a notice u/s. 154 of the Act seeking
assessee fulfils
all the conditions stipulated in sub -section (2), the section
would be applicable. These conditions do not require an asses-
see to maintain ... whether the assessee fulfils all the
conditions of section 80-IB and, in particular, sub-section (2)
thereof. It would be relevant, for instance, while
limitation. Section 150(2) of the Act could not save the limitation as limitation
had already expired on the date of issue of notice ... Controls v. Smt. Sneha
Joshi & Ors. , 355 ITR 102 (Bom) held that under the present section 147 , no
action could be taken after expiry
asst. years 2010-11 and 2011-12, the assesee claimed deduction u/s
10B of the Income-tax Act, 1961 (in short ... 355/- claimed by the assessee u/s 10B of the Act for
asst. years 2010-11 and 2011-12 respectively. The assessments were
accordingly completed
