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3 results for “disallowance”+ Permanent Establishmentclear

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Key Topics

Section 2636Section 403Section 9(1)(vii)3Section 112Section 10A2Deduction2

M/S. DEVICE DRIVEN (INDIA) PVT. LTD. vs. THE COMMISSIONER OF INCOME TAX

ITA/257/2014HC Kerala13 Oct 2020

Bench: HONOURABLE MR.JUSTICE K.VINOD CHANDRAN,HONOURABLE MR. JUSTICE T.R.RAVI

Section 10ASection 10BSection 143(1)Section 195Section 40Section 9(1)(vii)

disallowed under Section 40(a)(i) of the Act. The dis-allowance under Section 40(a)(i) was on the ground that the commission paid was fees for technical services on which tax is deductible at source, which the assessee failed to deduct. The amount shown as commission paid to the non-resident was added to I.T.A.No

THE RAHABILITATION PLANTATION LTD. vs. COMMISSIONER OF INCOME TAX

Appeal is allowed in part as indicated above

ITA/37/2018HC Kerala04 Aug 2022

Bench: The Income Tax Appellate Tribunal, Cochin Bench. The Subject Matter Of Appeal Relates To Assessment Year 2008-09 & The Controversies Relate To The Allowance Claimed By The Assessee Towards The Replantation Of Rubber Plants In An Area Where Rubber Trees Were Planted & Have Become Unproductive & Are Not In An Abandoned Area As Required By Rule 7A (2) Of The Income Tax Rules 1962, The Deduction Of Expenditure Incurred Towards Upkeep & Maintenance Of Rubber Saplings Till Maturity Or The Trees Yield & The Loss Incurred At The Rubber Sheet Factory.

For Appellant: THE REHABILITATION PLANTATION LTDFor Respondent: COMMISSIONER OF INCOME TAX
Section 10(31)Section 37

permanently useless? ii) Whether the interpretation given by the Appellate Tribunal to Rule 7A(2) contrary to the express provisions of the said Rule? iii) Whether the Appellate Tribunal was right in disallowing the loss claimed by the Appellant from rubber sheet factory? iv) Whether the Appellate Tribunal erred in not allowing the prior period expenses, paid by the appellant

THE COMMISSIONER OF INCOME-TAX(EXEMPTIONS) vs. M/S CHOICE FOUNDATION

ITA/180/2019HC Kerala11 Nov 2021

Bench: HONOURABLE MR.JUSTICE S.V.BHATTI,HONOURABLE MR.JUSTICE BASANT BALAJI

Section 11Section 11(5)Section 12Section 13(8)Section 143(3)Section 148Section 154Section 2(24)(iia)Section 260ASection 263

establishment of the capital asset by the assessee. Through order in Annexure-B order 22.12.2016, the Commissioner held as follows: “4. I have gone through the submissions made by the assessee during the course of the proceedings u/s 263 of the Income Tax Act and I find that the assessee has not adduced any convincing reply to the proposed revision