Investment Co. Ltd. v. ACIT

14 SOT 80Income Tax Appellate Tribunal2007#22497 most cited
3

judgments rely on this decision, according to BharatTax’s citation analysis of 346,713 Indian tax judgments — from 2018 to 2022.

Judgments citing Investment Co. Ltd. v. ACIT

Toyota Kirloskar Auto Parts Private Limited, Ramanagara vs. Assistant Commissioner of Income Tax, Ltu, Circle-2, Bangalore

In the result, the appeal is treated as partly allowed

ITA 301/BANG/2021[2016-17]Status: DisposedITAT Bangalore23 May 2022AY 2016-17

Bench: Shri N. V. Vasudevan & Shri Laxmi Prasad Sahuit(Tp)A No.301/Bang/2021 Assessment Year : 2016-17 M/S. Toyota Kirloskar Auto Parts Pvt. Ltd., Acit, Vs. Plot No.21 Bidadi Industrial Area, Circle –2, Ltu, Bidadi, Ramanagara, Bengaluru. Bengaluru-562 109. Pan : Aabct 5590 Q Appellant Respondent

For Appellant: Shri. K. R. Vasudevan, AdvocateFor Respondent: Shri. Pradeep Kumar, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 92

…rridden by the statutory provision". Thus, the Court has unequivocally held that DDT is a tax on the company and not on the shareholder. A similar position has been consistently upheld by the ITAT Mumbai in the case of Sunash Investment Co v. Asstt. CIT[2007] 14 SOT 80 (Mum. -Trib.), Mohananlal M. Shah v. thy. CIT[2007] 105 ITD 669 (Mum) and Asstt. CIT v. Dakshesh S. Shah [2004] 90 I TD 519 (Mum).A similar argument on applicability of tax treaty to DDT was considered and rejected by the South African High Court in the case of Volkswagen of South Africa (Pty) Ltd. CIT South African Revenue Service [Case No.24201/2…

Hycron Electronics vs. Dy.Commissioner of Income Tax

Appeal of the Revenue is dismissed and appeal of the assessee is allowed

ITA 1217/CHANDI/2016[2010-11]Status: DisposedITAT Chandigarh06 Mar 2018AY 2010-11

Bench: Smt. Diva Singh & Dr. B.R.R. Kumar

For Appellant: NoneFor Respondent: Dr. Gulshan Raj
Section 14ASection 250(6)Section 271Section 271(1)Section 271(1)(c)Section 80Section 80I

…nhance the loss in the return of income by ignoring the provision contained in section 14A. Therefore, it can be said that the assessee has furnished an explanation which is bona fide. (Page 60 to 64 of paper book) ii.Sunash Investment Co. Ltd. v. ACIT[2007] 14 SOT 80 (Mum.) (Trib.) -When Assessee claimed deduction of interest on borrowed funds which were invested in the financing business as well as purchase of shares of group companies under bona fide belief that such interest was deductible in entirety in view of some judicial 6 pronouncements, it cannot be said that the assessee is guilty of concealment or…

DCIT, Parwanoo vs. M/S Hycron Electronics, Solan

Appeal of the Revenue is dismissed and appeal of the assessee is allowed

ITA 1195/CHANDI/2016[2011-12]Status: DisposedITAT Chandigarh06 Mar 2018AY 2011-12

Bench: Smt. Diva Singh & Dr. B.R.R. Kumar

For Appellant: NoneFor Respondent: Dr. Gulshan Raj
Section 14ASection 250(6)Section 271Section 271(1)Section 271(1)(c)Section 80Section 80I

…nhance the loss in the return of income by ignoring the provision contained in section 14A. Therefore, it can be said that the assessee has furnished an explanation which is bona fide. (Page 60 to 64 of paper book) ii.Sunash Investment Co. Ltd. v. ACIT[2007] 14 SOT 80 (Mum.) (Trib.) -When Assessee claimed deduction of interest on borrowed funds which were invested in the financing business as well as purchase of shares of group companies under bona fide belief that such interest was deductible in entirety in view of some judicial 6 pronouncements, it cannot be said that the assessee is guilty of concealment or…

Investment Co. Ltd. v. ACIT (14 SOT 80) — Cited in 3 Judgments | BharatTax