ITAT Mumbai held that Corporate Guarantee facility provided to overseas AE by the assessee is an international transaction and hence addition towards Arm’s Length Guarantee Fee confirmed.
Karnataka High Court held that payments made to Non-resident Telecom Operators for provision of bandwidth and Inter-connectivity Usage Charge are not covered as Royalty/ FTS and, accordingly, TDS not deductible. Further, assessee is entitled to take benefit of DTAA between two countries.
ITAT Jaipur held that the difference in the closing stock is emanating from the difference in the working for the preceding years and that such difference cannot be attributed for the year under consideration. Accordingly, order not erroneous and jurisdiction of section 263 not invocable.
Jammu Kashmir High Court held that the extended period of limitation as provided under provision to sub -section (1) of Section 11A was not invocable for the simple reason that the twin factors which are sine quo non for invoking the proviso were missing.
Explore ITAT Raipur’s verdict on tax collection by District Mining Officer (DMO). Understand the implications of not collecting tax at source (TCS) on compounding fees from illegal miners/transporters. Analysis of Section 206C(1C) and obligations under the Income Tax Act.
ITAT Ahmedabad held that transfer pricing adjustment should be restricted only in respect of turnover of assessee-company relating to international transactions. In nut-shell, transfer pricing addition should be restricted only qua international transaction and not entity level transactions.
Gujarat High Court held that rejection of refund claim of unutilized ITC used in making zero-rated supply of goods merely on the ground of technicality unjustified as all the substantive conditions are satisfied.
Read the detailed analysis of ITAT Mumbai’s decision on DCIT Vs ICICI Bank Ltd., addressing disallowance of exempt income, inordinate delay, and the crucial role of interest-free funds.
ITAT Kolkata held that non-resident Indian who has provided services as an employee outside India (i.e. in Morocco) is entitled to claim benefit of Article 15(1) of the India Morocco DTAA.
ITAT Raipur held that addition towards unexplained investment unsustainable as AO failed to place on record any material which would conclusively establish that the said society was a benamidar of the assessee. Accordingly, addition based on bald allegation couldn’t be accepted.
