19 PwC tax partners have resigned following the resignation of the PwC tax head Dinesh Kanabar on Saturday December 26. Among the people who quit today are H Kotak, G Mistry and R Dhume – all of whom have joined KPMG. All the resigning partners were originally from RSM.
The US watchdog has charged Ernst & Young and six of its current and former partners for their roles at a fitness business, for failing to know about its fraudulent financial accounting and disclosures. E&Y in the US issued unqualified audit opinions stating that Bally’s 2001 to 2003 financial statements confirmed with GAAP, and its audit conformed with accepted auditing standards.
While the statute is to be interpreted on the basis of the; plain language or terms of the sections need for interpretation when the words of the statute are ambivalent and do not manifest the intention of the Legislature. As explained above the interpretation canvassed by the assessee will lead to unintended results if the purpose for which the section is introduced is kept in mind. Therefore in our option a purposive approach has to be adopted in interpreting the provisions of sec 80 RR.
The services/activities provided by the American Institute to DRDO pursuant to the agreement entered into between FICCI and the American Institute do not fall within the purview of Article 12(4)(b) of the Indo-US DTAA and the payments received by the Institute under the agreement are not liable to be taxed as fees for technical services under the domestic law; consequently, FICCI is not required to deduct tax under section 195 for payments made by it to the American Institute.
The provisions of Explanation to section 73 do not distinguish between the transaction of trading in shares on actual delivery or without delivery basis. Admittedly the assessee does not fall under any of the exceptions provided in the Explanation and hence, the purchase and sale of shares traded during the year under consideration is in nature of speculation business within the meaning of proviso to section 73 of IT Act, 1961.
I have given my careful consideration to the rival contentions. The first issue, in my view, to be addressed in this case is as to the determination of annual letting value of the house property in accordance with the provisions of section 23(1)(a) of the Act. Once that issue is decided, then it will be easy to decide the second issue as to whether the earlier order of the Tribunal in assessee’s own case was necessarily to be followed or not.
But now, we have to consider the alternative claim of the assessee, whether the assessee is entitled for deduction u/s.37(1) of the Act, of donation made in lieu of appeal made by the GOG as the abovementioned amount was paid because Gujarat State was reeling under severe drought and one of the most important assets of the poor people of Gujarat i.e., cattle would be lost which would result in permanent loss to a large number of farmers and others, whose dependence on cattle were substantial. The company made payment to suppliers, who gave fodder directly to various cattle camps as directed by the GOG. The assessee-company paid this amount on the direction of GOG for keeping smooth relation with the gov
The Supreme Court would decide whether foreign airlines are liable to deduct tax at source (TDS) on commissions paid to travel agents for rendering ticketing services. The issue for consideration before the apex court is if airlines would have to deduct TDS on the difference between the full value of tickets and the concessional tickets issued to their travel agents.
Air travel agents will have to forego a part of the commission they receive from airlines on tickets sold by them, as the tax department has decided that such payments will be subject to tax deduction at source, or TDS. This could increase cost of air travel, as agents will pass on this burden to the flyer. The Central Board of Direct Taxes, the apex direct tax body, has directed its field officers to deduct tax at source on payment of commission to travel agents, a tax department official told.
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 and engaged in the business of hiring out drill-ship in India, is entitled to claim depreciation on the value of the drill-ship.
