The issue in dispute is that whether disallowance under Section 40(a)(ia) of the Income Tax Act, 1961 applies only to amount ‘payable’ on the year end or whether amount ‘paid’ during the year is also covered within its ambit. In this regard, Hon’ble Allahabad High Court in case of CIT vs. M/s Vector Shipping Services (P) Ltd., (2013) 262 CTR (All) 545 held that for attracting disallowance under the said section, the amount should be payable and not which has been paid by the end of the year.
The Export Promotion Capital Goods (EPCG) scheme was one of the several export-promotion initiatives launched by the Government in the early ’90s. The basic purpose of the scheme was to allow exporters to import machinery and equipment at affordable prices so that they can produce quality products for the export market.
Whether the amounts paid by the ONGC to the non-resident assessees /foreign companies for providing various services in connection with prospecting, extraction or production of mineral oil is chargeable to tax as fees for technical services under Section 44D read with Explanation 2 to Section 9(1)(vii) of the Income Tax Act
Whether certain govt. agencies (ONGC) in agreement with foreign companies would entitle for the exemption of surtax under notification no. GSR 307 (E) dated 3.1983.
The Constitution (122nd Amendment) Bill, 2014 was introduced in the Lok Sabha on December 19, 2014 by the MoF which seeks to amend the Constitution to introduce GST. GST is a simplified indirect tax structure, wherein tax paid on goods/services procured by one person at one stage can be availed as credit while passing on the goods/services to the next stage, until they reach the final consumer who bears incidence of tax.
Transfer Pricing is the setting of the price for goods and services sold between controlled/related legal entities. It is generally aimed at depicting favourable performance of a conglomerate by shifting earnings from a high tax jurisdiction to a low-tax one.
In view of the retrospective amendment introduced by Finance Act, 2010, the appellant were entitled to reverse the proportionate cenvat credit attributable to the quantum of input services used in or in relation to manufacture of exempted final product and by foregoing this credit
The reserve, which is required to be created under Section 45-IC, is out of the profits earned by a non-banking financial institution. It is not an amount diverted at source by overriding title. The Reserve Bank of India Act, 1934 can permit appropriation in respect of the said reserve.
The Revenue’s argument seems plausible and even logical because the Commissioner or a Chief Commissioner is unarguably ranked higher in authority than a Joint Commissioner. Yet at the same time
In the present case, there is no doubt at all that the assessee cooperated and appeared both in the assessment as well as reassessment proceedings. Therefore, it had deemed notice of the re-assessment proceedings.
