SHARP BUSINESS SYSTEM THR. FINANCE DIRECTOR MR. YOSHIHISA MIZUNO vs. COMMISSIONER OF INCOME TAX-III N.D

The appeals are hereby disposed of in terms of

Bench: HON'BLE MR. JUSTICE MANOJ MISRA

3) of the Act the claim of 17 depreciation on non-compete fee was disallowed by following the earlier order of assessment in the case of the assessee itself for the assessment year 1999-2000 holding that the expenditure was in no way connected with the acquisition of various assets. The disallowance in this regard was worked

MANSAROVAR COMMERCIAL PVT. LTD. vs. COMMISSIONER OF INCOME TAX DELHI

Bench: HON'BLE MR. JUSTICE M.R. SHAH

3) would indicate that the seat of such power may be divided between two distinct and separate places. The expression “control and management” means de facto control and management and not merely the right or power to control and manage. In order to hold that a non- Indian company is resident in India during any previous year, it must