The Assessing Officer has made disallowance of Rs. 2.63 Crores under Section 40(a)(i) on account of non-deduction of tax at source on the payments made to nonresident translators. The authorities below have held translation services to be technical in nature.
‘(AA) after the proviso, but before Explanation 1, the following proviso shall be inserted with effect from the 1st day of April, 2015, namely:- “Provided further that in case of a share of company (not being a share listed in a recognised stock exchange) or a unit of a
Investment by company: A company shall unless otherwise prescribed, make investment through not more than two layers of investment companies except – if ; (i) a company from acquires any other company incorporated in a country outside India if such other company has investment subsidiaries beyond two layers as per the laws of such country;
We saw a deluge of analyses coming on Budget 2014 right from 11th July 2014. However, we chose to wait for clarifications and finer details so that readers get the right perspective for themselves. People would have different opinion about the budget depending on their own profession and field. However, from investor and taxpayers point […]
CBDT via Notification No. 33 dated 25th July 2014, had made some changes in Form 3CA, 3CB and 3CD. Via these changes the compliances which a CA is required to ensure and disclosures which are required to be made by a Chartered Accountants has been increased.
The existing Form No. 3CA, Form No. 3CB and Form No. 3CD have been substituted vide notification no. 33/2014 dated 25.07.2014 with immediate effect. Taxpayers and CAs are advised to await the release of the new schema and utility to submit in the newly notified aforementioned Forms. Taxpayers and CAs are advised that any upload […]
CA Sandeep Kanoi CBDT has vide notification no. 33/2014 dated 25.07.2014 revised the format of Tax Audit Report to be furnished under section 44AB of the Income tax Act with effect from 25.07.2014. We have compiled below the key amendments made to the old Form 3CD:- 1. Particulars of registration under excise duty, service tax, […]
The Revenue officers must realize that just like other powers a executive power conferred in them is in the nature of a Trust. They hold office as trustees of the public at large. They deal with public revenue and public money and that cannot be wasted in such frivolous litigation. We, therefore, dismiss these appeals with costs quantified at Rs.1,00,000/ each.
CBDT has revised in the mid of tax season format of Tax Audit Report to be submitted in Form 3CD vide its Notification No. 33/2014, Dated: July 25, 2014. The revised report has added some new clauses to increase disclosure requirement and as well amended few clauses to further increase/improve disclosure requirements. Revised Tax Audit […]
On careful consideration of above contention, we are of the view that there may be a substantive assessment without any protective assessment but there can not be any protective assessment/addition without a substantive assessment/addition, meaning thereby there has to be some substantive assessment/addition first which enables the AO to make a protective assessment/addition.