INCOME TAX REPORTS (ITR)
Volume 336 : Part 4 (Issue dated 29-8-2011)
SUBJECT INDEX TO CASES REPORTED IN THIS PART
Offences and prosecution --False verification in return--Burden of proof--Return--Signature on return filed by firm--Partner at no point of time during assessment or penalty proceedings or in appeal therefrom disputing signature on return--Conduct amounting to admission of signature--Department need not prove signature in prosecution--Income-tax Act, 1961, ss. 271(1)(a), (c), 276C, 277, 278-- ITO v. Mangat Ram Norata Ram Narwana . . . 624
Appeal to Appellate Tribunal --Duty of Tribunal--Additional evidence--Additional evidence necessary for deciding case--Duty of Tribunal to consider additional evidence--Income-tax Act, 1961-- CIT v. Mukta Metal Works (P&H) . . . 555
Appeal to High Court --Appeal from single order of Tribunal in a batch of cases--Single appeal to High Court maintainable--But court fees payable in respect of each appeal which stands consolidated--Income-tax Act, 1961, s. 260A-- Director, Income-tax (International Taxation) v. Transocean Offshore International Ventures Ltd. (Uttarakhand) . . . 637
Assessment --Draft assessment order--Concurrent jurisdiction conferred under section 125A--Effect--Draft order to be sent to IAC having concurrent jurisdiction--Order passed by Assessing Officer under directions of that IAC--Valid--Income-tax Act, 1961, ss. 125A, 144B-- CIT v. Saraya Sugar Mills P. Ltd . (All) . . . 572
Block assessment --Conditions precedent--Block assessment of third person--Condition precedent--Satisfaction that such other person had undisclosed income and forwarding of material to officer having jurisdiction--Failure--Assessment on other person not valid--Income-tax Act, 1961, s. 158BD-- CIT v. Sunil Bhala (Delhi) . . . 550
Business expenditure --Weighted deduction--Expenditure incurred on scientific research--Notification of article or thing--Assessee entitled to weighted deduction for whole year, not merely from date of notification--Prescribed authority approving existence of research and development facility and expenditure incurred on such scientific research--Assessee entitled to expenditure incurred for whole of assessment year--Income-tax Act, 1961, s. 35(2AB)-- CIT v. Wheels India Ltd . (Mad) . . . 513
Charitable purpose --Charitable trust--Registration--Meaning of "charitable purpose"--Agricultural marketing committee constituted by State to protect agriculturists--Object of general public utility--Agricultural marketing committee is a person--Entitled to registration under section 12A/12AA--Income-tax Act, 1961, ss. 11, 12A, 12AA-- CIT v. Agricultural Market Committee (AP) . . . 641
Co-operative society --Banking business--Special deduction--Interest--Income from investment of voluntary reserves--Entitled to deduction--Income-tax Act, 1961, s. 80P(2)(a)(i)-- CIT v. Andhra Pradesh State Co-operative Bank Ltd . (AP) . . . 516
Deduction of tax at source --Payment to non-resident--Royalty--Definition--Difference between DTAA and Act--Transfer of know-how from UK company to Indian company--Agreement for complete transfer of know-how and not merely its use--UK company not having permanent establishment in India--Amount remitted to UK company not assessable in India--Tax not to be deducted at source on such remittance--Income-tax Act, 1961, s. 9(1)(vi), Expln. 2--Double Taxation Avoidance Agreement between India and the U. K-- CIT v. D. C. M. Ltd . (Delhi) . . . 599
Income-tax --General principles--Mention of wrong provision would not by itself render order invalid-- Dr. V. S. Chauhan v. Director of Income-tax (Investigations ) (All) . . . 533
Offences and prosecution --Purchase of immovable property by Central Government--Failure to file Form 37-I by purchaser of immovable property--Notice not necessary before launching prosecution--Income-tax Act, 1961, ss. 269UC, 276AB, 278B--Code of Criminal Procedure, 1973, ss. 397, 482-- Rattan Singh Gupta v. State (Delhi) . . . 629
----Purchase of immovable property by Central Government--Failure to file Form 37-I by purchaser of immovable property--Territorial jurisdiction of High Court--Notification under Income-tax Act vesting jurisdiction in Appropriate Authority in Delhi to deal with cases in Delhi and Faridabad--Transfer of immovable property in Faridabad--Delhi High Court could consider complaint pertaining to transfer--Income-tax Act, 1961, ss. 269UC, 276AB, 278B--Code of Criminal Procedure, 1973, ss. 177, 178-- Rattan Singh Gupta v. State (Delhi) . . . 629
Reassessment --Notice--Validity of notice--Writ--Powers of High Court--High Court can find out whether there was material to believe that income had escaped assessment--Revised computation of income submitted by assessee in assessment proceedings--Recomputation correct and accepted as such by Assessing Officer--That revised statement submitted beyond time specified in section 139(5) and therefore invalid, not a ground for commencement of reassessment proceedings--Income-tax Act, 1961, ss. 147, 148--Constitution of India, art. 226-- Rotary Club of Ahmedabad v. Asst. CIT (Guj) . . . 585
Recovery of tax --Attachment and sale of property--Writ--Existence of alternative remedy--Writ will not normally issue--Joining of all parties necessary--Recovery proceedings against property standing in name of trust having three beneficiaries--Writ petition by only two beneficiaries--Writ petition not maintainable--Income-tax Act, 1961--Constitution of India, art. 226-- Sagar Sharma v. Addl. CIT (Bom) . . . 611
Search and seizure --Block assessment--Assessment of third person--Effect of section 158BD--Material during search indicating undisclosed income of third person--Further investigation not necessary--Presumption under section 292C applicable--Office note of Assessing Officer regarding undisclosed income of third person--Notice under section 158BD--Valid--Income-tax Act, 1961, s. 158BD-- CIT v. Mukta Metal Works (P&H) . . . 555
----Validity--Discovery of investment in construction of huge hospital--Search valid--Subsequent notice under section 131(1A)--Error in mention of provision--Notice actually under section 133(6)--Notice would not invalidate search--Income-tax Act, 1961, ss. 132, 133-- Dr. V. S. Chauhan v. Director of Income-tax (Investigations) (All) . . . 533
Writ --Delay--No reasonable explanation for delay--Writ may not be issued--Constitution of India, art. 226-- Dr. V. S. Chauhan v. Director of Income-tax (Investigations) (All) . . . 533
SECTIONWISE INDEX TO CASES REPORTED IN THIS PART
Code of Criminal Procedure, 1973 :
S. 177 --Offences and prosecution--Purchase of immovable property by Central Government--Failure to file Form 37-I by purchaser of immovable property--Territorial jurisdiction of High Court--Notification under Income-tax Act vesting jurisdiction in Appropriate Authority in Delhi to deal with cases in Delhi and Faridabad--Transfer of immovable property in Faridabad--Delhi High Court could consider complaint pertaining to transfer-- Rattan Singh Gupta v. State (Delhi) . . . 629
S. 178 --Offences and prosecution--Purchase of immovable property by Central Government--Failure to file Form 37-I by purchaser of immovable property--Territorial jurisdiction of High Court--Notification under Income-tax Act vesting jurisdiction in Appropriate Authority in Delhi to deal with cases in Delhi and Faridabad--Transfer of immovable property in Faridabad--Delhi High Court could consider complaint pertaining to transfer-- Rattan Singh Gupta v. State (Delhi) . . . 629
S. 397 --Offences and prosecution--Purchase of immovable property by Central Government--Failure to file Form 37-I by purchaser of immovable property--Notice not necessary before launching prosecution-- Rattan Singh Gupta v. State (Delhi) . . . 629
S. 482 --Offences and prosecution--Purchase of immovable property by Central Government--Failure to file Form 37-I by purchaser of immovable property--Notice not necessary before launching prosecution-- Rattan Singh Gupta v. State (Delhi) . . . 629
Art. 226 --Reassessment--Notice--Validity of notice--Writ--Powers of High Court--High Court can find out whether there was material to believe that income had escaped assessment--Revised computation of income submitted by assessee in assessment proceedings--Recomputation correct and accepted as such by Assessing Officer--That revised statement submitted beyond time specified in section 139(5) and therefore invalid, not a ground for commencement of reassessment proceedings-- Rotary Club of Ahmedabad v. Asst. CIT (Guj) . . . 585
----Recovery of tax--Attachment and sale of property--Writ--Existence of alternative remedy--Writ will not normally issue--Joining of all parties necessary--Recovery proceedings against property standing in name of trust having three beneficiaries--Writ petition by only two beneficiaries--Writ petition not maintainable-- Sagar Sharma v. Addl. CIT (Bom) . . . 611
----Writ--Delay--No reasonable explanation for delay--Writ may not be issued-- Dr. V. S. Chauhan v. Director of Income-tax (Investigations) (All) . . . 533
S. 9(1)(vi), Expln. 2 --Deduction of tax at source--Payment to non-resident--Royalty--Definition--Difference between DTAA and Act--Transfer of know-how from UK company to Indian company--Agreement for complete transfer of know-how and not merely its use--UK company not having permanent establishment in India--Amount remitted to UK company not assessable in India--Tax not to be deducted at source on such remittance--Double Taxation Avoidance Agreement between India and the U. K-- CIT v. D. C. M. Ltd . (Delhi) . . . 599
S. 11 --Charitable purpose--Charitable trust--Registration--Meaning of "charitable purpose"--Agricultural marketing committee constituted by State to protect agriculturists--Object of general public utility--Agricultural marketing committee is a person--Entitled to registration under section 12A/12AA-- CIT v. Agricultural Market Committee (AP) . . . 641
S. 12A --Charitable purpose--Charitable trust--Registration--Meaning of "charitable purpose"--Agricultural marketing committee constituted by State to protect agriculturists--Object of general public utility--Agricultural marketing committee is a person--Entitled to registration under section 12A/12AA-- CIT v. Agricultural Market Committee (AP) . . . 641
S. 12AA --Charitable purpose--Charitable trust--Registration--Meaning of "charitable purpose"--Agricultural marketing committee constituted by State to protect agriculturists--Object of general public utility--Agricultural marketing committee is a person--Entitled to registration under section 12A/12AA-- CIT v. Agricultural Market Committee ( AP) . . . 641
S. 35(2AB) --Business expenditure--Weighted deduction--Expenditure incurred on scientific research--Notification of article or thing--Assessee entitled to weighted deduction for whole year, not merely from date of notification--Prescribed authority approving existence of research and development facility and expenditure incurred on such scientific research--Assessee entitled to expenditure incurred for whole of assessment year-- CIT v. Wheels India Ltd . (Mad) . . . 513
S. 80P(2)(a)(i) --Co-operative society--Banking business--Special deduction--Interest--Income from investment of voluntary reserves--Entitled to deduction-- CIT v. Andhra Pradesh State Co-operative Bank Ltd . (AP) . . . 516
S. 125A --Assessment--Draft assessment order--Concurrent jurisdiction conferred under section 125A--Effect--Draft order to be sent to IAC having concurrent jurisdiction--Order passed by Assessing Officer under directions of that IAC--Valid-- CIT v. Saraya Sugar Mills P. Ltd . (All) . . . 572
S. 132 --Search and seizure--Validity--Discovery of investment in construction of huge hospital--Search valid--Subsequent notice under section 131(1A)--Error in mention of provision--Notice actually under section 133(6)--Notice would not invalidate search-- Dr. V. S. Chauhan v. Director of Income-tax (Investigations) (All) . . . 533
S. 133 --Search and seizure--Validity--Discovery of investment in construction of huge hospital--Search valid--Subsequent notice under section 131(1A)--Error in mention of provision--Notice actually under section 133(6)--Notice would not invalidate search-- Dr. V. S. Chauhan v. Director of Income-tax (Investigations) (All) . . . 533
S. 144B --Assessment--Draft assessment order--Concurrent jurisdiction conferred under section 125A--Effect--Draft order to be sent to IAC having concurrent jurisdiction--Order passed by Assessing Officer under directions of that IAC--Valid-- CIT v. Saraya Sugar Mills P. Ltd . (All) . . . 572
S. 147 --Reassessment--Notice--Validity of notice--Writ--Powers of High Court--High Court can find out whether there was material to believe that income had escaped assessment--Revised computation of income submitted by assessee in assessment proceedings--Recomputation correct and accepted as such by Assessing Officer--That revised statement submitted beyond time specified in section 139(5) and therefore invalid, not a ground for commencement of reassessment proceedings-- Rotary Club of Ahmedabad v. Asst. CIT (Guj) . . . 585
S. 148 --Reassessment--Notice--Validity of notice--Writ--Powers of High Court--High Court can find out whether there was material to believe that income had escaped assessment--Revised computation of income submitted by assessee in assessment proceedings--Recomputation correct and accepted as such by Assessing Officer--That revised statement submitted beyond time specified in section 139(5) and therefore invalid, not a ground for commencement of reassessment proceedings-- Rotary Club of Ahmedabad v. Asst. CIT (Guj) . . . 585
S. 158BD --Block assessment--Conditions precedent--Block assessment of third person--Condition precedent--Satisfaction that such other person had undisclosed income and forwarding of material to officer having jurisdiction--Failure--Assessment on other person not valid-- CIT v. Sunil Bhala (Delhi) . . . 550
----Search and seizure--Block assessment--Assessment of third person--Effect of section 158BD--Material during search indicating undisclosed income of third person--Further investigation not necessary--Presumption under section 292C applicable--Office note of Assessing Officer regarding undisclosed income of third person--Notice under section 158BD--Valid-- CIT v. Mukta Metal Works (P&H) . . . 555
S. 260A --Appeal to High Court--Appeal from single order of Tribunal in a batch of cases--Single appeal to High Court maintainable--But court fees payable in respect of each appeal which stands consolidated-- Director, Income-tax (International Taxation) v. Transocean Offshore International Ventures Ltd (Uttarakhand) . . . 637
S. 269UC --Offences and prosecution--Purchase of immovable property by Central Government--Failure to file Form 37-I by purchaser of immovable property--Notice not necessary before launching prosecution-- Rattan Singh Gupta v. State (Delhi) . . . 629
----Offences and prosecution--Purchase of immovable property by Central Government--Failure to file Form 37-I by purchaser of immovable property--Territorial jurisdiction of High Court--Notification under Income-tax Act vesting jurisdiction in Appropriate Authority in Delhi to deal with cases in Delhi and Faridabad--Transfer of immovable property in Faridabad--Delhi High Court could consider complaint pertaining to transfer-- Rattan Singh Gupta v. State (Delhi) . . . 629
S. 271(1)(a), (c) --Offences and prosecution--False verification in return--Burden of proof--Return--Signature on return filed by firm--Partner at no point of time during assessment or penalty proceedings or in appeal therefrom disputing signature on return--Conduct amounting to admission of signature--Department need not prove signature in prosecution-- ITO v. Mangat Ram Norata Ram Narwana (SC) . . . 624
S. 276AB --Offences and prosecution--Purchase of immovable property by Central Government--Failure to file Form 37-I by purchaser of immovable property--Notice not necessary before launching prosecution-- Rattan Singh Gupta v. State (Delhi) . . . 629
----Offences and prosecution--Purchase of immovable property by Central Government--Failure to file Form 37-I by purchaser of immovable property--Territorial jurisdiction of High Court--Notification under Income-tax Act vesting jurisdiction in Appropriate Authority in Delhi to deal with cases in Delhi and Faridabad--Transfer of immovable property in Faridabad--Delhi High Court could consider complaint pertaining to transfer-- Rattan Singh Gupta v. State (Delhi) . . . 629
S. 276C --Offences and prosecution--False verification in return--Burden of proof--Return--Signature on return filed by firm--Partner at no point of time during assessment or penalty proceedings or in appeal therefrom disputing signature on return--Conduct amounting to admission of signature--Department need not prove signature in prosecution-- ITO v. Mangat Ram Norata Ram Narwana (SC) . . . 624
S. 277 --Offences and prosecution--False verification in return--Burden of proof--Return--Signature on return filed by firm--Partner at no point of time during assessment or penalty proceedings or in appeal therefrom disputing signature on return--Conduct amounting to admission of signature--Department need not prove signature in prosecution-- ITO v. Mangat Ram Norata Ram Narwana (SC) . . . 624
S. 278 --Offences and prosecution--False verification in return--Burden of proof--Return--Signature on return filed by firm--Partner at no point of time during assessment or penalty proceedings or in appeal therefrom disputing signature on return--Conduct amounting to admission of signature--Department need not prove signature in prosecution-- ITO v. Mangat Ram Norata Ram Narwana (SC) . . . 624
S. 278B --Offences and prosecution--Purchase of immovable property by Central Government--Failure to file Form 37-I by purchaser of immovable property--Notice not necessary before launching prosecution-- Rattan Singh Gupta v. State (Delhi) . . . 629
----Offences and prosecution--Purchase of immovable property by Central Government--Failure to file Form 37-I by purchaser of immovable property--Territorial jurisdiction of High Court--Notification under Income-tax Act vesting jurisdiction in Appropriate Authority in Delhi to deal with cases in Delhi and Faridabad--Transfer of immovable property in Faridabad--Delhi High Court could consider complaint pertaining to transfer-- Rattan Singh Gupta v. State (Delhi) . . . 629
ITR'S TRIBUNAL TAX REPORTS (ITR (TRIB))
Volume 11 : Part 1 (Issue dated : 29-08-2011)
SUBJECT INDEX TO CASES REPORTED IN THIS PART
Appeal to Appellate Tribunal --Special Bench--Question referred to Special Bench pending consideration before High Court--Special Bench not precluded from deciding reference--Income-tax Act, 1961, ss. 158A, 255-- Deputy CIT v. Summit Securities Ltd. [SB] (Mumbai) . . . 88
Business expenditure --Depreciation--Firm--Assessment--Interest paid to partners--Assessee not providing depreciation in books whereby--Disallowance of interest to partners by reworking capital account balances of partners--Assessee cannot be compelled to provide for depreciation in books of account--Deduction of interest payment made to partners to be allowed--Income-tax Act, 1961, ss. 32, 40(b) --Swaraj Enterprises v. ITO (Visakhapatnam) . . . 70
----Repair and maintenance of machinery--Commissioner (Appeals) right in deleting disallowance of sixty per cent. of expenditure claimed--Income-tax Act, 1961-- Deputy CIT v. Rakesh Jain (Chandigarh) . . . 82
Capital or revenue receipt --Interest awarded by High Court--Capital receipt--Income-tax Act, 1961--CBDT Circular No. 14 (XL-35), dated 11-4-1955-- Sushil Kumar Das v. ITO (Kolkata) . . . 17
Charitable purposes --Charitable trust--Denial of exemption--Investment of funds otherwise than in specified form--Loans given to another charitable institution--No investment of funds--Loan not out of accumulated surplus of accounting year--Exemption cannot be denied--Income-tax Act, 1961, ss. 11, 13-- Kanpur Subhash Shiksha Samiti v. Deputy CIT (Lucknow) . . . 23
Depreciation --Rate of depreciation--Modification of wooden partitions and work stations in premises taken on lease--Temporary structure-- 100 per cent. depreciation allowable--Income-tax Act, 1961, s. 32--Income-tax Rules, 1962, Appendix I, item 4-- Deputy CIT v. Win Medicare Ltd. (Delhi) . . . 66
----Rate of depreciation--Tippers, vibrators, vibrator soil compactor are commercial vehicles--Higher rate of 40 per cent. allowable--Income-tax Act, 1961, s. 32 -- Deputy CIT v. Rakesh Jain (Chandigarh) . . . 82
Income-tax --General principles--Amount erroneously offered to tax--Assessee entitled to raise plea before appellate authorities against its assessment-- Sushil Kumar Das v. ITO (Kolkata) . . . 17
Penalty --Concealment of income--Transactions in securities--Purchase of units with dividend and sale within three months of record date without dividend--Dividend income claimed exempt--Claim for loss on sale of units against other taxable income--Relevant particulars and basic facts necessary for applying provisions of section 94(7) not disclosed in return--Penalty to be imposed--Income-tax Act, 1961, ss. 94(7), 271(1)(c) -- Survidhi Financial Services Ltd. v. Asst. CIT (Delhi) . . . 49
Search and seizure --Block assessment--Penalty--Assessing Officer making addition and imposing penalty--Addition not made on basis of any evidence found during search--Penalty cannot be imposed--Income-tax Act, 1961, ss. 158BFA(2), 158BB(1)-- Beena Rani v. Deputy CIT (Delhi) . . . 106
----Block assessment--Undisclosed income--Assessment of third person--No recording of satisfaction that undisclosed income belonged to third person--Amounts disclosed in returns of such persons--Additions in hands of third persons--Not valid--Income-tax Act, 1961, s. 158BD-- Asst. CIT v. Bhagwan Prasad (Ranchi) . . . 1
Words and phrases --"Undisclosed income", "Satisfaction"-- Asst. CIT v. Bhagwan Prasad (Ranchi) . . . 1
SECTIONWISE INDEX TO CASES REPORTED IN THIS PART
S. 11 -- Charitable purposes--Charitable trust--Denial of exemption--Investment of funds otherwise than in specified form--Loans given to another charitable institution--No investment of funds--Loan not out of accumulated surplus of accounting year--Exemption cannot be denied-- Kanpur Subhash Shiksha Samiti v. Deputy CIT (Lucknow) . . . 23
S. 13 -- Charitable purposes--Charitable trust--Denial of exemption--Investment of funds otherwise than in specified form--Loans given to another charitable institution--No investment of funds--Loan not out of accumulated surplus of accounting year--Exemption cannot be denied-- Kanpur Subhash Shiksha Samiti v. Deputy CIT (Lucknow) . . . 23
S. 32 -- Business expenditure--Depreciation--Firm--Assessment--Interest paid to partners--Assessee not providing depreciation in books whereby--Disallowance of interest to partners by reworking capital account balances of partners--Assessee cannot be compelled to provide for depreciation in books of account--Deduction of interest payment made to partners to be allowed-- Swaraj Enterprises v. ITO (Visakhapatnam) . . . 70
---- Depreciation--Rate of depreciation--Modification of wooden partitions and work stations in premises taken on lease--Temporary structure-- 100 per cent. depreciation allowable-- Deputy CIT v. Win Medicare Ltd. (Delhi) . . . 66
---- Depreciation--Rate of depreciation--Tippers, vibrators, vibrator soil compactor are commercial vehicles--Higher rate of 40 per cent. allowable-- Deputy CIT v. Rakesh Jain (Chandigarh) . . . 82
S. 40(b) -- Business expenditure--Depreciation--Firm--Assessment--Interest paid to partners--Assessee not providing depreciation in books whereby--Disallowance of interest to partners by reworking capital account balances of partners--Assessee cannot be compelled to provide for depreciation in books of account--Deduction of interest payment made to partners to be allowed-- Swaraj Enterprises v. ITO (Visakhapatnam) . . . 70
S. 94(7) -- Penalty--Concealment of income--Transactions in securities--Purchase of units with dividend and sale within three months of record date without dividend--Dividend income claimed exempt--Claim for loss on sale of units against other taxable income--Relevant particulars and basic f1acts necessary for applying provisions of section 94(7) not disclosed in return--Penalty to be imposed-- Survidhi Financial Services Ltd. v. Asst. CIT (Delhi) . . . 49
S. 158A -- Appeal to Appellate Tribunal--Special Bench--Question referred to Special Bench pending consideration before High Court--Special Bench not precluded from deciding reference-- Deputy CIT v. Summit Securities Ltd. [SB] (Mumbai) . . . 88
S. 158BB(1) -- Search and seizure--Block assessment--Penalty--Assessing Officer making addition and imposing penalty--Addition not made on basis of any evidence found during search--Penalty cannot be imposed-- Beena Rani v. Deputy CIT (Delhi) . . . 106
S. 158BD -- Search and seizure--Block assessment--Undisclosed income--Assessment of third person--No recording of satisfaction that undisclosed income belonged to third person--Amounts disclosed in returns of such persons--Additions in hands of third persons--Not valid-- Asst. CIT v. Bhagwan Prasad (Ranchi) . . . 1
S. 158BFA(2) -- Search and seizure--Block assessment--Penalty--Assessing Officer making addition and imposing penalty--Addition not made on basis of any evidence found during search--Penalty cannot be imposed-- Beena Rani v. Deputy CIT (Delhi) . . . 106
S. 255 -- Appeal to Appellate Tribunal--Special Bench--Question referred to Special Bench pending consideration before High Court--Special Bench not precluded from deciding reference-- Deputy CIT v. Summit Securities Ltd. [SB] (Mumbai) . . . 88
S. 271(1)(c) -- Penalty--Concealment of income--Transactions in securities--Purchase of units with dividend and sale within three months of record date without dividend--Dividend income claimed exempt--Claim for loss on sale of units against other taxable income--Relevant particulars and basic facts necessary for applying provisions of section 94(7) not disclosed in return--Penalty to be imposed-- Survidhi Financial Services Ltd. v. Asst. CIT (Delhi) . . . 49
Appendix I, item 4 -- Depreciation--Rate of depreciation--Modification of wooden partitions and work stations in premises taken on lease--Temporary structure-- 100 per cent. depreciation allowable-- Deputy CIT v. Win Medicare Ltd. (Delhi) . . . 66
CA.RAJU SHAH
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