HARISH KUMAR CHANDNANI,BHOPAL vs. INCOME TAX OFFICER -3(1), BHOPAL, BHOPAL

Appeal is allowed

capital gain'. The above transaction is 'adventure in the nature of trade' and profit\narising out of above transaction is chargeable as 'business profit' of the assessee-society.\n10.4 As discussed in preceding paras, since the impugned sale transaction is 'adventure\nin the nature of trade', the contention of the assessee-society that the impugned lands are\n'rural agricultural

DEVENDRA CHOKSEY,BHOPAL vs. THE PR CIT-1, BHOPAL

In the result, appeal of assessee is allowed

Bench: Shri Chandra Mohan Garg & Shri Bhagirath Mal Biyaniassessment Year: 2016-17 Devendra Chouksey, Pr. Cit-1, Aayakar Bhawan, 20/8, Shalimar Enclave, 48, Arera Hills, Hoshangabad Near Under Bridge, E-3, Vs. Road, Bhopal 462011 Arera Colony, Bhopal 462016 Pan Abapc5311R (Appellant) (Respondent)

221(5) TIM 485 ITAT Chandigarh and ITAT Delhi Bench in the case of Balvinder Kumar vs PCIT reported as (2021) 125 taxmann.com 83 held that in a case of limited scrutiny the Assessing Officer could not go beyond the reason for which the matter was selected for limited scrutiny. Thus it would not be opened to PCIT to pass

COMPUTER SCIENCES CORPORATION INDIA PRIVATE LIMITED,CHENNAI vs. ACIT, CHENNAI

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year: 2007-08 Computer Sciences Acit, Corporation India Private Company Circle 1(3), Limited, Chennai [Formerly Covansys (India) Private Limited], बनाम/ Unit 13, Block 2, Sdf Buildings, Vs. Madras Export Processing Zone, Tambaram, Chennai (Assessee / Appellant) (Revenue / Respondent) Pan: Aaacc1351M Assessee By Shri Neeraj Jain, Adv. Shri Abhishek Agrawal, Ca Revenue By Shri P.K. Mishra, Cit Dr Date Of Hearing 12.07.2023 Date Of Pronouncement

section 32(1) by making a sufficient note in assessment-order. Consequently, we uphold AO’s action. The assessee fails in this ground. Ground No. 23: 32. This ground relates to the cost of Rs. 73,10,920/- incurred by assessee towards licensed software treated by AO as capital expenditure. 33. The assessee has incurred cost towards purchase of licensed