Trinity Global Enterprises Ltd. vs. ITO: No disallowance under 40A(2) for supervision and risk management charges. Detailed analysis and conclusions provided.
In a landmark ruling, the Calcutta High Court exempts tea saplings from Bengal Agricultural Income Tax Act. Learn the detailed analysis of Gouranga Parbati Tea Co. Pvt. Ltd. Vs. Agricultural Income Tax Officer & Ors.
Pragati Power Corporation Ltd vs ACIT (ITAT Delhi) case: Analysis of ITAT decision allowing deduction under section 80IA without offsetting losses from other Industrial Units.
ITAT Kolkata held that foreign Associated Enterprises are least complex entities and accordingly can be treated as tested parties for comparability analysis of international transaction.
ITAT Visakhapatnam has held that if working capital adjustment on ALP has been already factored in pricing/ profitability vis-à-vis that of its comparables, then, no separate upward adjustment on outstanding receivables is required.
ITAT Mumbai held that business restructuring entered into by an enterprise with its associated enterprise for eliminating duplicate corporate procedures falls within the ambit of “international transaction” as defined in section 92B of the Income Tax Act.
ITAT Delhi held that as non-renewal doesn’t amount to termination, accordingly, receipt of compensation on account of non-renewal of contract cannot be taxed under section 28(ii)(e) of the Income Tax Act.
ITAT Bangalore held that if the duration of software license is less than two years, then it should be treated as revenue expenditure and if the duration is more than two years, then it should be treated as capital expenditure.
Delhi High Court held that charges relating to clandestine removal and undervaluation of goods cannot be sustained merely on the basis of assumptions and presumptions. Accordingly, addition rightly deleted.
ITAT Bangalore held that addition under section 69 of the Income Tax Act unjustified as source of fund duly explained. Rejection of the explanation relating to source of fund by the department without sufficient reason is unsustainable in law.
