audit report) serial No. 28(a) is factually incorrect.
He has filed before us a copy of the audit report in Form No. 3CD,
which ... petitioner to explain:-
"In audit report u/s 44AB , clause 28(a)
shows that 138 items of Micrographic software
has been used-in-house
Director Of Income Tax vs M/S E Funds It Solution on 5 February, 2014
equipments with softwares
developed by the petitioner pre-installed on this hardware. The products
are special purpose equipments and hence, the software of propriety
nature ... Sick Industrial Companies (SP) Act, 1985, on basis of
audited accounts as on 30-09-2013. The following
deficiencies are observed:
(a) The Directors Report
engaged in the business of
development of software for the parent company in the field of
telecommunication. The respondent had filed return of income ... Associated Enterprise" details of which were mentioned in the tax
audit report, the matter was referred to Transfer Pricing Officer (TPO)
to determine
draft order. However, preliminary objections were raised against initiation
of special audit proceedings.
8. As per the respondents, notices under Section ... furnished in SAP format could not be accessed by using an accounting
software and had to be converted, and hence cannot be termed as production
Company is very peculiar and contention the
stock details in tax audit different from other trading or manufacturing Ld AO regarding
report for the year ... purchases of IT equipments, and opening and
consideration and non software and license are from reputed OEMs (Original closing stock are
existence of closing stock
Commissioner Of Income Tax-I vs M/S Cotton Naturals (I) Pvt. Ltd. on 27
Sony Ericsson Mobile Communications ... vs Commissioner Of Income Tax ??? Iii on 16 March, 2015
Author
Pr. Commissioner Of Income Tax -6, New ... vs Ndr Promoters Pvt. Ltd. on 17 January
Nitisha vs Union Of India on 25 March, 2021
Author: D.Y. Chandrachud
Bench: D