CIT v. Satish Kumar Chandna

M/S CONTINENTAL CARRIERS vs. COMMISSIONER OF INCOME TAX

Bench: HON'BLE DR. JUSTICE S.MURALIDHAR,HON'BLE MR. JUSTICE VIBHU BAKHRU

…ntended that it was incumbent upon the ITAT to consider all the facts, both for and against the Assessee, before rejecting the contentions or material submitted by the Assessee. He also relied on the decision of this Court in CIT v. Satish Kumar Chandna: 311 ITR 276 (Del) in support of the aforesaid contention. Reasoning and Conclusion 18. The question of law before us is a limited one and, that is, whether the conclusion of the ITAT with regard to the apportionment of expenses to determine the Foreign Income for the purposes of deduction under Section 80-O of the Act, is inconsistent with the evid…

M/S CONTINENTAL CARRIER vs. COMMISSIONER OF INCOME TAX

Bench: HON'BLE DR. JUSTICE S.MURALIDHAR,HON'BLE MR. JUSTICE VIBHU BAKHRU

…ntended that it was incumbent upon the ITAT to consider all the facts, both for and against the Assessee, before rejecting the contentions or material submitted by the Assessee. He also relied on the decision of this Court in CIT v. Satish Kumar Chandna: 311 ITR 276 (Del) in support of the aforesaid contention. Reasoning and Conclusion 18. The question of law before us is a limited one and, that is, whether the conclusion of the ITAT with regard to the apportionment of expenses to determine the Foreign Income for the purposes of deduction under Section 80-O of the Act, is inconsistent with the evid…

M/S CONTINENTAL CARRIER vs. COMMISSIONER OF INCOME TAX

…ntended that it was incumbent upon the ITAT to consider all the facts, both for and against the Assessee, before rejecting the contentions or material submitted by the Assessee. He also relied on the decision of this Court in CIT v. Satish Kumar Chandna: 311 ITR 276 (Del) in support of the aforesaid contention. Reasoning and Conclusion 18. The question of law before us is a limited one and, that is, whether the conclusion of the ITAT with regard to the apportionment of expenses to determine the Foreign Income for the purposes of deduction under Section 80-O of the Act, is inconsistent with the evid…