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4 results for “disallowance”+ Section 172(4)clear

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Key Topics

Section 54B7Section 143(3)4Section 40A(3)3Survey u/s 133A3Section 234C2Section 69A2Permanent Establishment2

DCIT (INTERNATIONAL TAXATION), DEHRADUN vs. M/S. SAMSUNG HEAVY INDUSTRIES CO. LTD., GURGAON

In the result, appeal of the assessee in ITA No

ITA 1315/DEL/2017[2008-09]Status: DisposedITAT Dehradun22 Dec 2023AY 2008-09
Section 143(3)Section 234C

4. The income has been computed by the ld AO after holding „inside India revenue‟ of Rs. 60,89,46,384/- and “outside India revenue” of Rs. 643,19,18,042/-, being income attributable to „inside India Operations‟ and to the Indian Permanent Establishment (PE) and income computed at profit rate of 25% thereof. While doing

SAMSUNG HEAVY INDUSTRIES CO. LTD.,GURGAON vs. DCIT (INTERNATIONAL TAXATION), DEHRADUN

In the result, appeal of the assessee in ITA No

ITA 873/DEL/2017[2012-13]Status: DisposedITAT Dehradun22 Dec 2023AY 2012-13
Section 143(3)
Section 234C

4. The income has been computed by the ld AO after holding „inside India revenue‟ of Rs. 60,89,46,384/- and “outside India revenue” of Rs. 643,19,18,042/-, being income attributable to „inside India Operations‟ and to the Indian Permanent Establishment (PE) and income computed at profit rate of 25% thereof. While doing

DEPUTY COMMISSIONER OF INCOME TAX (CENTRAL CIRCLE), DEHRADUN, DEHRADUN vs. STONEFIELD CONSTRUCTION, DEHRADUN, DEHRADUN

In the result, appeal of the Revenue is partly allowed

ITA 215/DDN/2025[2023-24]Status: DisposedITAT Dehradun08 Apr 2026AY 2023-24
Section 115BSection 133ASection 139Section 143(3)Section 250Section 250(2)Section 40A(3)Section 40aSection 69ASection 69C

disallowance made by the AO. Ground of appeal No.2 raised by the Revenue is thus dismissed. 12. Grounds of appeal Nos. 3 & 4 raised by the Revenue are with respect to the findings of ld. CIT(A) in disregarding the action of AO in treating the additional income of INR 3.89 crores offered during the course of survey on account

SH. DEVENDRA DUTT PANT,HARIDWAR vs. DCIT , UTTARKAHAND

Appeal is partly allowed in above terms

ITA 149/DDN/2025[2106-2017]Status: DisposedITAT Dehradun14 Jan 2026AY 2106-2017

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwal

For Appellant: Sh. Salil Aggarwal, Sr. Adv. &For Respondent: Sh. A. S. Rana, Sr. DR
Section 133(6)Section 143(3)Section 54BSection 54E

172 ITR 95 a Division Bench of the Bombay High Court, of which one of us (S.P. Bharucha, J.) was a member, considered this question again. In this case the assessee had purchased the land of an extent of seven acres in February 1966. The land was covered by the Nagpur Improvement Trust Scheme. In August 1966 he obtained permission