valuation report

Applicability of year end rate for conversion of business income earned in foreign currency

This article summarizes ruling of the Delhi Income Tax Appellate Tribunal (ITAT) in the case of DCIT v Dolphin Drilling Pte. Ltd. (Taxpayer) [2009-TIOL-754- 1TAT-DEL]. The ITAT held that the conversion of business income earned in foreign currency into INR, in accordance with Rule 115 (Rule) of the Indian Tax Law (ITL), is to be made by adopting the conversion rate prevailing at the end of the tax year. It also held that the Taxpayer, a company incorporated in Singapore ..
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Section 55A of the Income-tax Act, 1961 related Capital gains and Reference to Valuation Officer

SUMMARY OF CASE LAW Whether by invoking section 55A, Assessing Officer can disturb sale consideration – Held, no - Whether for invoking section 55A there has to be a claim made by assessee, before Assessing Officer can record opinion either under clause (a) or clause (b) of section 55A to make a reference to Valuation [...]
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Section 195 of IT Act, 1961 is applicable even when deductee is a foreign company and assessed in India due to its business presence in India

SUMMARY OF CASE LAW Section 195 nowhere mentioned that a foreign company, who is being assessed in India on account of its business presence, will be exempt from section 195. CASE LAW DETAILS Decided by ITAT, BANGALORE BENCH `A’, In The case of: ITO (Int’l Taxation) v. Intel Tech India Pvt. Ltd., Appeal No.: ITA [...]
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