ITAT held that in case A comparable having an extraordinary financial event of Merger and Acquisition (M& A) during the year the same cannot be considered as functionally comparable for transfer pricing (TP) comparability analysis.
Mobileum Inc Vs DCIT (ITAT Mumbai) since transactions between the assessee and its AE have been found at arm’s length prices no further income chargeable to tax in India can be said to be attributable for the PE of the assessee. FULL TEXT OF THE ORDER OF ITAT MUMBAI This appeal by the Assessee is […]
Magadh Sugar & Energy Ltd. Vs State of Bihar & Ors. (Supreme Court of India) Writ petitions were filed in the High Court challenging the levy. The writ petitions were dismissed on the ground that an alternative remedy of a statutory appeal was available. An appeal against these orders was filed before this Court. The […]
Income Tax Act, is the only Act in which there are bound to change in Budget of Central Government, every year. We know that there are FIVE heads of Income under the Income Tax Act since so many years and accordingly income is to be calculated. These heads are as under: 1. Salary Income: Under […]
DCIT Vs Singhania Buildcon Pvt. Ltd. (ITAT Raipur) 1. AO has not made any attempt to rebut the claim of the assessee. The confirmations were filed by the assessee to support the factual position. The assessee has placed the facts which are apparent in nature for which no rebuttal has been done. 2. The Hon’ble […]
SERVICE EXPORTERS: CLAIM YOUR INCENTIVE AS PER FOREIGN TRADE POLICY Service Exports India Scheme is an incentive scheme as per the Foreign Trade Policy which aims at rewarding the service exporters. ELIGIBILITY: All the service providers as per the Appendix 3X notification No 29/2015-20 dated 23/9/2021 for the year 2019-20 and Appendix 3D/3E for other […]
Understanding the Applicability of Section 206AB & 206CCA Provision from 01st July 2021. Know how these new sections affect TDS/TCS rates for non-filers of Income Tax Returns.
Highlight: -As per the new orders, Aadhaar-based e-KYC process has been reintroduced for issuing new mobile connections. -Telecom service providers will be charged Re 1 per customer authentication by the UIDAI. -Customer consent has been made compulsory in case the Aadhaar is being used and demographic details are being obtained electronically from UIDAI. -Telecom reforms […]
The case of the assessee was decided ex-parte u/s 144 of the Income Tax Act, 1961 in which a demand of Rs. 2320480/- has been created which is quite huge, illegal, baseless and not justified. A very small trader cannot earn so much income that he has to pay tax liability of Rs. 2320480/-. Comparison can be made with the returns filed earlier.
The PLI Scheme for the auto sector envisages to overcome the cost disabilities of the industry for manufacture of Advanced Automotive Technology products in India. The incentive structure will encourage industry to make fresh investments for indigenous global supply chain of Advanced Automotive Technology products.