citation
relied upon we hold the view that the statutory provisions of section 92 CA(3)
are clear as far timelines of 60 days available ... While doing so the assesse himself allowed an amount of
Rs.16,452 u/s 14A r.w Rule 8D. The AO relying upon Apex
have wrongly held that for
the purpose of computing deduction under sec 80IA of the Act,
unabsorbed depreciation losses of the preceding assessment years ... impugned assessment year, it claimed
deduction of 1,62,15,452/- under section 80IA(4)(iv)(a) of the 'Act'
qua income from
admitting a loss of Rs. 28,54,452/- and the same was processed under Section 143(1) of the Act on 27.2.2004 accepting the loss
proviso to
clause (a) to sub-section(1) of Section 275 of the Act, the time limit
available for the assessing officer, taking into account ... clause (a) to sub-
section (1) of Section 275 of the Act in isolation of the provisions of
Sec
definition of section 2(47) of the Act.
Accordingly, the Assessing Officer treated the amount of ₹.2,38,63,452/-
received from Elior India ... asset under section 2(47) of the Act and the transfer is liable to capital
gains under section 45(1) of the Act and relied
definition of section 2(47) of the Act.
Accordingly, the Assessing Officer treated the amount of ₹.2,38,63,452/-
received from Elior India ... asset under section 2(47) of the Act and the transfer is liable to capital
gains under section 45(1) of the Act and relied
justified in confirming the order passed under section 201 / 201(1A) of the
Income Tax Act, 1961 ["Act" in short] in the facts ... concession)
amounting to ₹.1,85,452/- involving travel places outside India. The
Assessing Officer observed that the exemption under section
been
provided towards bad and doubtful debts. Hence, the deduction u/s
36(1)(viia) should be restricted only to that extent and deduction
allowed ... under estimated by an amount of Rs.33,21,08,452/- thereby excess
deduction allowed
substantive conditions of Section 194C(6) of the Act, which exempts
the requirement of TDS deduction.
:-2-: ITA. No:452/Chny/2025 ... Section 194C(6) & (7) are independent of
each other and cannot read together to attract disallowance under Section 40(a)(ia)
read with Section
Appeals), Addl./JCIT(A), Thane (in short "FAA") passed u/s.
250 of the Income Tax Act, 1961 (in short ... unexplained investment u/s 69A of the Income Tax
Act, 1961 and taxed at the rates specified under Section under Section
115BBE of the Income
