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“Section 205(6)”

Section References (mined)Section 205Section 205(6)1 judgments

The decision most relied on for Section 205(6) is CIT v. Sophia Finance Ltd. (205 ITR 98), cited in 295 judgments on BharatTax.

Leading authorities on Section 205(6)

CIT v. Sophia Finance Ltd.
205 ITR 98 · 1994 · High Court
295
citing judgments

To discharge the burden of proof under Section 68 for share capital or share application money, an assessee must establish the identity of the shareholders and the genuineness of the transaction, confirming that the payment was truly made by them.

Set Satellite Pte Ltd. v. CIT
307 ITR 205 · 2008 · High Court
96
citing judgments

If a Dependent Agency Permanent Establishment (DAPE) is remunerated at arm's length based on transfer pricing principles, no further profits can be attributed to the foreign enterprise. The principles of profit attribution under DTAA Article 7 are pari-materia to Section 9(1)(i) of the Income Tax Act.

Judgments citing Section 205(6)

Tulsibhai Kashiram Patel, Mehsana vs. The Income Tax Officer, Ward-5, Patan

In the result, appeal preferred by the assessee is allowed for statistical purposes

ITA 1033/AHD/2023[2012-13]Status: DisposedITAT Ahmedabad22 Mar 2024AY 2012-13

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./I.T.A. No. 1033/Ahd/2023 ("नधा"रण वष" / Assessment Years : 2012-13)

For Respondent: None
Section 143(3)Section 205(6)

notices, the appeal stood dismissed ex parte. Needless to mention that the issues were not disposed of on merit in terms of Section 205(6) of the Act which is duty incumbent upon the Ld. CIT(A) as per such statutory provision of ITA No. 1033/Ahd/2023 (Tulsibhai Kashiram Patel