Here is Portfolio page of Ankur, with all his work

Works manager & supervisors held to be in category of workers, HC
Dec. 24, 2015
Assessee mfd. polythene bags & tubes. It claimed deduct'n u/s 80-IB. Assessee employed only 8 workers in manufacturing process, AO disallowed deduct'n. On appeal CIT(A) & ITAT allowed it. On appeal ITAT upheld it holding, works manager is like highly technical qualified worker having managerial responsibility, likewise, supervisor is also like highly skilled supervisory worker. Therefore, both these persons fall within the categories of wor…
Lifting of corporate veil by AO held in breach of principles of natural justice
Dec. 08, 2015
Tax dues were pending upon assessee, director of ltd Co. AO issued notice u/s 179 to recover outstanding dues. Assessee objected, as he was director of public ltd. Co. AO held that if conditions were satisfied for lifting of corporate veil, he could take public Ltd. Co. as pvt. ltd. Co. On writ, HC held, AO order based on lifting of corporate veil even if it is, would be in breach of principles of natural justice & hence, can't be sustained.&nb…
AO held erroneous in invoking Sec. 43 for determining actual cost in deal.
Nov. 02, 2015
Assessee acquired business of EMD at slump price. AO found, assessee enhanced value of assets as WDV of assets shown & disallowed excess depreciation. On appeal, CIT(A) held, there was no question of evading tax liability by assessee even if lower depreciation was granted. On appeal, ITAT upheld order of CIT(A). On appeal, HC upheld CIT(A) & ITAT decision stating that assessee had no income for it to reduce its tax liabilities by way of transfer.-0…
Amounts held includible in total receipt u/s 44BB for levy of tax at 10% rate.
Dec. 10, 2015
Assessee NR Co. explored & produced in India. It declared its revenues on account of two contracts with 'X' Co. & offered its receipts to tax at rate 10% according to proviso. of Sec. 44BB. AO rejected it & included amounts in total receipt. In light of CIT v. Halliburton Offshore Services Inc. [2008] 300 ITR 265, CIT held, both amts. are includible in total receipt provided u/s 44BB for levy of tax at rate of 10%. ITAT upheld it on app…
As assessees had insufficient cause, thus delay in filling case was not condoned
Dec. 11, 2015
In search, documents, a/c books & papers seized from office of assessees. AO issued notice u/s 153A for block assessm't proceedings. AO passed assessm't order by making addit'ns. CIT(A) & ITAT upheld AO's order. On appeal HC found, assessees have not shown sufficient cause for condoning delay. Parameters laid down by SC in in Esha Bhattacharjee v. Managing Committee of Raghunathpur, Nafar Academy 2013 (5) CTC 547 delay held not to be condon…
Int. income earned on fixed deposits as income from other sources fell u/s 80HHC
Nov. 04, 2015
Assessee imported & sold timber. Assessee had interest income earned on money lent to other parties. AO treated it as 'income from other sources. Assessee alleged it as 'business income. On appeals CIT & Tribunal rejected it. On appeal HC upheld it stating, interest income earned on fixed deposits, treated as income from other sources, hence, it is to be considered in calculation to be done in accordance with clause (baa) of Sec. 80HHC. -010593
CIT(A) method to arrive at fair market value of plot, held better, ITAT
Dec. 24, 2015
Assessee-Co. sold its factory land. It reported fair market value (FMV) of land at Rs.14.12 cr. on basis of report of reg. valuer &, worked out capital gain. AO valued it 1.7 cr on basis of unused land. CIT(A) rejected assesse's valuation report & calulated FMV 2.78 cr. On appeal ITAT held, CIT(A) had adopted probable method for arriving at FMV of plot & that annual rate of appreciat'n method. His method held better than method adopted …
Assessee directed to show records on which change in accounting policy made.
Nov. 23, 2015
Assessee filed return declaring loss. Assessment completed u/s 143(3) &Sec.115JB. AO reopened assessment on ground of no change in accounting policy regarding dep. AO made addit'n to book profit on account of applying reduced rate of dep. CIT(A) upheld it. On appeal ITAT held, issue on merits is set aside to record of AO for deciding afresh after verification & examination of relevant record, which assessee has not produced before AO & Tribunal.-00…
Section 66, 67(o) Finance Act held ultra vires to contitution, SC
Apr. 08, 2016
On writ HC held, Sec. 66, 67(o) of Finance Act, 1994 & other provisions related to Kalyana Mandapams & Mandap-Keepers to be intra vires of Constitution of India. On writ SC held, it has been a well established judicial principle that so long as legislation is in substance, on matter assigned to legislature enacting that statute, it must be held valid in its entirety even though it may trench upon matters beyond its competence.
Deduct'n calim u/s 80-IB(10) on housing project allowed to assessee, HC
Dec. 08, 2015
Assessee-HUF claimed deduct'n u/s 80-IB(10) on housing project. AO disallowed it. On appeal, CIT(A) allowed it holding that assessee need not own property to claim deduct'n u/s 80-IB(10) & car park area would not be held as private area. On appeal, Tribunal upheld it. On appeal HC upheld it too as in proviso. no justification in including car park in definit'n of built-up area of residential unit for purpose of determining maximum built-u…