ITAT Delhi held that attribution of profit from offshore supply and services to the Permanent Establishment unsustainable as assessee didn’t have any Permanent Establishment in India in the assessment years under dispute.
ITAT Mumbai held that Nostro Account Maintenance Charges are in the nature of bank charges levied on transaction and the same are not subject to tax deduction at source u/s. 195 of the Act. Accordingly, disallowance of the same by invoking provisions of Section 40(a)(i) of the Act unjustified.
Bombay High Court held that filing of refund application u/s. 27 of the Customs Act after more than two years of date on which excess duty payment was done is clearly beyond the period of one year as contemplated by the Customs Act and hence is barred by limitation.
ITAT Delhi held that as there is no copyright on live events, the license fees for live and non-live transmission right cannot be taxed as royaty in terms of section 9(1)(vi) of the Income Tax Act. Accordingly, addition deleted.
Bombay High Court held that reopening of assessment u/s 147 of the Income Tax Act unsustainable as the assessee has fully and truly disclosed all the material facts.
ITAT Mumbai held that deduction claimed u/s. 80P(2)(d) of the Income Tax Act cannot be denied by invoking another sub-section of 80P. Accordingly, disallowance of deduction claimed u/s 80P deleted.
ITAT Bangalore held that the interest income earned by a cooperative society on its investments held with a cooperative bank would be eligible for claim of deduction under Sec.80P(2)(d) of the Income Tax Act.
ITAT Mumbai held that reopening of assessment under section 147 of the Income Tax Act based on information received by AO from DDIT (investigation) justified subject to fulfilment of conditions as envisaged u/s 147/148.
ITAT Mumbai held that disallowance on account of delayed payments of PF and ESI contribution unjustified as payment made well before the due date of filing of income tax return u/s. 139(1).
ITAT Jaipur held that ignorance of law and bona fide belief cannot be termed as sufficient cause and hence condonation of delay in filing of an appeal not granted.
