VIDRES INDIA CERAMICS PVT. LTD.,,AHMEDABAD vs. THE DY. CIT, CIRCLE-4(1)(2),, AHMEDABAD

In the result, assessee’s appeal is allowed

Bench: Shri Pramod Kumar & Ms. Madhumita Roy

Section 36(1)(vii) in as much as the assessee is covered by SC decision in the case of CIT vs. Vijya Bank 323 ITR 166 (SC).” 2. Ground No.1 : At the time of hearing of the instant appeal the Learned Counsel appearing for the assessee submitted before us that he does not want to proceed with this ground

M/S.HDB FINANCIAL SERVICES LTD.,,AHMEDABAD vs. THE PR. CIT-1 , AHMEDABAD

In the result, the appeal filed by the Assessee is hereby allowed

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

vii) and 36(1)(viia), directly set aside the assessment order passed by the Ld. AO, which is beyond the scope of powers conferred u/s 263 of the Act. 10.1. Thus the very same issue what was considered by the Ld. A.O. in the assessment proceedings is revised by the Ld. PCIT on the ground that

SABRI CHEMICALS PVT. LTD.,,BARODA vs. THE ACIT, CIRCLE-2(1)(1),, BARODA

In the result, the appeal of the assessee is partly allowed for the statistical purposes

Bench: Shri Waseem Ahmed & Smt Madhumita Royआयकर अपील सं./I.T.A. No. 1019/Ahd/2016 ("नधा"रण वष" / Assessment Year : 2012-13) Sabri Chemicals Pvt. Ltd., Acit, बनाम/ A/2/236, Gidc, Nandesari, Circle 2(1)(1), Vs. Baroda – 391 340. Baroda. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaccs 9406 K .. (अपीलाथ"/Appellant) (""यथ" / Respondent) Shri M. J. Shah, A.R. अपीलाथ" ओर से/ Appellant By : Shri Lalit P. Jain, Sr. D.R. ""यथ" क" ओर से/Respondent By:

section 36(1)(vii) of the Income-tax Act, 1961, with effect from April 1,1989, in order to obtain a deduction in relation to bad debts, it is not necessary for the assessee to establish that the debt, in fact, has become irrecoverable: it is enough if the bad debt is written off as irrecoverable in the accounts

SHELL INTERNATIONAL B.V., ,AHMEDABAD vs. THE ACIT, INTL. TAXN.-1, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

36. The scope of the term “make available” was discussed at length in the case of Raymond Ltd. v. Dy. CIT [2003] 86 ITD 791, in the following words: “Whereas Section 9(1)(vii ) stops with the ‘rendering’ of technical services, the DTA goes further and qualifies such rendering of services with words to the effect that the services

M/S. SHELL INTERNATIONAL B.V.,,MUMBAI vs. THE DY. CIT, INTL. TAXN.-1,, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

36. The scope of the term “make available” was discussed at length in the case of Raymond Ltd. v. Dy. CIT [2003] 86 ITD 791, in the following words: “Whereas Section 9(1)(vii ) stops with the ‘rendering’ of technical services, the DTA goes further and qualifies such rendering of services with words to the effect that the services

SHELL INTERNATIONAL B.V., ,MUMBAI vs. THE ACIT, INTL. TAXN.-2, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

36. The scope of the term “make available” was discussed at length in the case of Raymond Ltd. v. Dy. CIT [2003] 86 ITD 791, in the following words: “Whereas Section 9(1)(vii ) stops with the ‘rendering’ of technical services, the DTA goes further and qualifies such rendering of services with words to the effect that the services

M/S. SHELL INTERNATIONAL B.V.,,MUMBAI vs. THE DY. CIT, INTL. TAXN.-1,, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

36. The scope of the term “make available” was discussed at length in the case of Raymond Ltd. v. Dy. CIT [2003] 86 ITD 791, in the following words: “Whereas Section 9(1)(vii ) stops with the ‘rendering’ of technical services, the DTA goes further and qualifies such rendering of services with words to the effect that the services

SHELL INTERNATIONAL B.V., ,MUMBAI vs. THE ACIT, INTL. TAXN.-1,, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

36. The scope of the term “make available” was discussed at length in the case of Raymond Ltd. v. Dy. CIT [2003] 86 ITD 791, in the following words: “Whereas Section 9(1)(vii ) stops with the ‘rendering’ of technical services, the DTA goes further and qualifies such rendering of services with words to the effect that the services

M/S. SHELL INTERNATIONAL B.V., ,MUMBAI vs. THE DY. CIT, INTL. TAXN.-1,, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

36. The scope of the term “make available” was discussed at length in the case of Raymond Ltd. v. Dy. CIT [2003] 86 ITD 791, in the following words: “Whereas Section 9(1)(vii ) stops with the ‘rendering’ of technical services, the DTA goes further and qualifies such rendering of services with words to the effect that the services

SHELL INTERNATIONAL B.V.,MUMBAI vs. THE ACIT, INT.TAXA.-2, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

36. The scope of the term “make available” was discussed at length in the case of Raymond Ltd. v. Dy. CIT [2003] 86 ITD 791, in the following words: “Whereas Section 9(1)(vii ) stops with the ‘rendering’ of technical services, the DTA goes further and qualifies such rendering of services with words to the effect that the services

SHELL INTERNATIONAL B.V., ,MUMBAI vs. THE ACIT, INTL. TAXN.-1,, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

36. The scope of the term “make available” was discussed at length in the case of Raymond Ltd. v. Dy. CIT [2003] 86 ITD 791, in the following words: “Whereas Section 9(1)(vii ) stops with the ‘rendering’ of technical services, the DTA goes further and qualifies such rendering of services with words to the effect that the services

M/S. SHELL INTERNATIONAL B.V.,,MUMBAI vs. THE DY. CIT, INTL. TAXN.-1,, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

36. The scope of the term “make available” was discussed at length in the case of Raymond Ltd. v. Dy. CIT [2003] 86 ITD 791, in the following words: “Whereas Section 9(1)(vii ) stops with the ‘rendering’ of technical services, the DTA goes further and qualifies such rendering of services with words to the effect that the services

M/S. SHELL INTERNATIONAL B.V.,MUMBAI vs. THE ACIT, INTL. TAXN.-2, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

36. The scope of the term “make available” was discussed at length in the case of Raymond Ltd. v. Dy. CIT [2003] 86 ITD 791, in the following words: “Whereas Section 9(1)(vii ) stops with the ‘rendering’ of technical services, the DTA goes further and qualifies such rendering of services with words to the effect that the services

NATIONAL DAIRY DEVELOPMENT BOARD,ANAND vs. THE DY.CIT, ANAND CIRCLE, ANAND

In the result, the appeals filed by the Revenue in ITA Nos

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

68,11,434/- towards monthly benefits, leading to double addition of the same amount both in A.Y. 2011-12 and in A.Y. 2012-13. The assessee is of the view that the aforesaid amount was allowable to the assessee under Section 37 of the Act and further, disallowance of the same amount in A.Y. 2012-13 would lead

NATIONAL DAIRY DEVELOPMENT BOARD,ANAND vs. THE DY.CIT, ANAND CIRCLE, ANAND

In the result, the appeals filed by the Revenue in ITA Nos

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

68,11,434/- towards monthly benefits, leading to double addition of the same amount both in A.Y. 2011-12 and in A.Y. 2012-13. The assessee is of the view that the aforesaid amount was allowable to the assessee under Section 37 of the Act and further, disallowance of the same amount in A.Y. 2012-13 would lead

NATIONAL DAIRY DEVELOPMENT BOARD,ANAND vs. THE DY.CIT, ANAND CIRCLE, ANAND

In the result, the appeals filed by the Revenue in ITA Nos

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

68,11,434/- towards monthly benefits, leading to double addition of the same amount both in A.Y. 2011-12 and in A.Y. 2012-13. The assessee is of the view that the aforesaid amount was allowable to the assessee under Section 37 of the Act and further, disallowance of the same amount in A.Y. 2012-13 would lead

NATIONAL DAIRY DEVELOPMENT BOARD,ANAND vs. THE DY.CIT, ANAND CIRCLE, ANAND

In the result, the appeals filed by the Revenue in ITA Nos

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

68,11,434/- towards monthly benefits, leading to double addition of the same amount both in A.Y. 2011-12 and in A.Y. 2012-13. The assessee is of the view that the aforesaid amount was allowable to the assessee under Section 37 of the Act and further, disallowance of the same amount in A.Y. 2012-13 would lead

NATIONAL DAIRY DEVELOPMENT BOARD,ANAND vs. THE DY.CIT, ANAND CIRCLE, ANAND

In the result, the appeals filed by the Revenue in ITA Nos

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

68,11,434/- towards monthly benefits, leading to double addition of the same amount both in A.Y. 2011-12 and in A.Y. 2012-13. The assessee is of the view that the aforesaid amount was allowable to the assessee under Section 37 of the Act and further, disallowance of the same amount in A.Y. 2012-13 would lead