Delhi ITAT deleted additions for Marketing/Reservation fees and Travel Agent Commission (TACP) for Six Continents Hotels. The Tribunal ruled the receipts were not FTS/FIS under the India-USA DTAA, applying the rule of consistency.
Delhi ITAT deleted a ₹30.65 lakh cash deposit addition made under Section 69A during demonetization. The source was proven to be a gift from the deceased grandmother’s savings of previously taxed rental income, preventing double taxation.
): The ITAT set aside a penalty of ₹4.25 lakh levied under Section 271C for non-deduction of TDS. Citing the Supreme Court ruling in U.S. Technologies International Pvt. Ltd., the Tribunal held that Section 271C applies only to the failure to deduct, not the late remittance of already deducted tax.
Delhi ITAT deleted a Rs.1000 crore addition made under Section 68 based solely on an SFIO report alleging circular fund rotation. The Tribunal upheld reopening but limited the addition to estimated commission income, ensuring parity with group cases.
The ITAT ruled that a reassessment order passed in the name of a deceased assessee is a curable irregularity, not void ab initio, provided the initial Section 148 notice was validly issued during the assessee’s lifetime.
ITAT Ahmedabad upheld PCIT’s revisionary order, ruling that AO’s failure to disallow interest (Rs.44.51 lakh) on unsecured loans (Rs.92 lakh) already deemed unexplained was an erroneous and prejudicial’ omission, not merely a difference of opinion.
ITAT Chennai admitted fresh documents including confirmations and bank statements for unsecured loans and advances, remanding the matter to AO for de novo assessment to ensure natural justice.
CBDT’s Circular 14/2025 extended the audit report date for AY 2025-26 to October 31, 2025. This move contradicts the IT Act’s design, which links the audit date to the return filing deadline, causing taxpayer uncertainty.
Indian start-ups finance growth using instruments like CCPS, venture debt, and iSAFE notes. Capital structure evolves with milestones, requiring sequencing of funds to minimize WACC, manage forex risk, and comply with FEMA/RBI rules.
The implementation of the Goods and Services Tax (GST) on July 1, 2017, signified a pivotal development in India’s fiscal and constitutional progression. More than merely a tax reform, the GST represented an ambitious endeavor in cooperative federalism, aiming to consolidate over a dozen central and state indirect taxes into a cohesive system. While it […]
