Delhi ITAT ruled that a negative lien is not a corporate guarantee, quashing the Rs.16.48 Cr transfer pricing adjustment under Section 92B. Negative lien imposes no repayment liability.
Mumbai ITAT rules capital gains on a foreign company’s share sale are non-taxable in India under Article 13(5) of the India-Singapore DTAA. TRC is conclusive proof.
The ITAT Jaipur sustains additions under Sec. 68 for bogus unsecured loans in Bagaria Trade Impex case, rejecting technical relief and confirming the assessee failed to prove creditor genuineness.
ITAT Delhi rules Section 148 notice invalid as escaped income not represented in an ‘asset’; reassessment quashed for being time-barred.
ITAT Delhi held that production of investor directors is not mandatory to prove genuineness of share capital. Additions under Section 68 and presumed 2% commission were deleted.
The ITAT Delhi ruled that a UK company’s receipts from Indian airlines for in-flight content are not taxable as royalty or fees for technical services, as no copyright or technical know-how was transferred.
Gujarat HC set aside an income tax reassessment order after the AO failed to consider the taxpayer’s detailed reply, emphasizing adherence to natural justice principles.
Tribunal rules that Mtitanium Apartments cannot claim ₹1.10 crore brought forward business losses as the income tax return for AY 2023-24 was filed late, despite medical hardship.
Supreme Court dismissed the SLP, affirming that ITAT rightly remanded the case to TPO to reassess ALP of intra-group services, stressing that Section 92C(3) conditions must be examined before adjustments.
Tribunal held that EDC paid to HUDA is a statutory levy and not interest, quashing disallowance u/s 40(a)(ia) based on erroneous application of Section 194A.
