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Commissioner of Income Tax vs. Wimco Seedlings Ltd. | Disallowance of Expenditure under Section 14A of the Income Tax Act, 1961 regarding Allocation of Common Expenses towards Taxable and Non-Taxable (Exempt) Income
Facts of the Case
Appeals
and Assessment Years: The Revenue (Commissioner of Income
Tax) filed three interconnected appeals (ITA Nos. 1367/2008, 1368/2008,
and 1391/2008) against a common judgment of ...
Commissioner of Income Tax vs. Wimco Seedlings Ltd.: Legal Validity of Allocating and Apportioning Common Business Expenses Incurred by an Assessee Toward Taxable and Non-Taxable Income Streams Under Section 14A of the Income Tax Act, 1961
Facts of the Case
The
Revenue filed three interconnected appeals (ITA Nos. 1367/2008, 1368/2008,
and 1391/2008) targeting a consolidated order passed by the Income Tax
Appellate Tribunal (Tribunal) on...
Commissioner of Income Tax vs. Wimco Seedlings Ltd.: Allocation of Common Expenses and Disallowance Under Section 14A of the Income Tax Act, 1961 – Scope of "In Relation To" and Application of Judicial Consistency vs. Precedent in Maxopp Investment Ltd.
Facts of the Case
The
Revenue filed three appeals against a common judgment of the Income Tax
Appellate Tribunal (ITAT) dated 22.02.2008.
The
appeals correspond to multiple assessment years: ITA No...
Commissioner of Income Tax v. M/s EHPT India Private Limited: Validity of Head-Count Method for Allocation of Indirect Expenses Between Tax-Exempt STP and Taxable Non-STP Units and the Applicability of the Rule of Consistency Under Section 10A of the Income-Tax Act, 1961
Facts of the Case
The
Assessee's Business: The respondent-assessee is a private
limited company resident in India. During the assessment years (AY)
2001-02 and 2002-03, it operated two distinct busine...
Commissioner of Income Tax vs. M/s Thirani Chemicals Ltd.: Whether Expansion of Existing Production Capacity Constitutes Setting Up of a New Industrial Undertaking for Eligibility of Deductions Under Sections 80HH and 80I of the Income Tax Act, 1961
Facts of the Case
Appeals
Filed: The revenue/appellant filed two appeals before the High
Court: ITA No. 1006/2005 (for the Assessment Year 1994-1995) and ITA
No. 457/2007 (for the Assessment Year 1996...
Commissioner of Income Tax vs. EHPT India P. Ltd. | Section 10A Indirect Expenses Apportionment: Head-Count vs. Turnover Method
Facts of the Case
The
Assessee: The respondent-assessee is an Indian private
limited company that operated two distinct divisions during the relevant
assessment years (AY 2001-02 and AY 2002-03):
...
Commissioner of Income Tax vs. EHPT India P. Ltd. | Section 10A Indirect Expenses Apportionment: Head-Count vs. Turnover Method
Facts of the Case
The
Assessee: The respondent-assessee is an Indian
private limited company that operated two distinct divisions during the
relevant assessment years (AY 2001-02 and AY 2002-03):
...
Commissioner of Income Tax vs. M/s Alankar Radio Equipments: Validity of Block Assessment Additions and the Application of the Telescoping Principle on Rotational Capital in High-Turnover Wholesale Cash Trades
Facts of the Case
The
Assessee: The respondent is a partnership firm
consisting of a father and son, primarily engaged in the wholesale
business of buying and selling audio cassettes belonging to Supe...
Mira Kulkarni vs. Assistant Commissioner of Income Tax: Allowability of Business Expenses Under Section 37(1) Absent Express Contractual Stipulation
Facts of the Case
Assessee
Profile & Agreement: The appellant, Mira
Kulkarni, is an individual and part-owner of an 11½-acre property located
at Anand Kashi Farms, Tehri Garwal, Uttaranchal. On A...
Commissioner of Income Tax vs. Integrated Technologies Ltd. | Section 32 of Income Tax Act, 1961: Allowance of Depreciation on "Passive Use" of Plant and Machinery During Temporary Lull in Business Activities
Facts of the Case
Assessee
& Return Filing: The assessee, a company engaged in
the manufacturing of printed circuit boards, filed its return of income
for the assessment year 2004–05 decla...