ITAT Mumbai rules SBI is not an assessee in default for TDS on foreign remittances if payees have paid taxes. Explains implications for MasterCard, Visa, and interest liability.
Bombay High Court rules against the Income Tax Department, stating that a reassessment notice issued after 4 years is invalid without a clear allegation of the assessee’s failure to disclose material facts.
The ITAT quashed a final assessment order against a company that no longer existed due to amalgamation, ruling the order void despite departmental knowledge of the merger.
The ITAT quashed an assessment against Karan Motors, ruling it was void because the Income Tax Department failed to prove the ACIT’s jurisdiction to act as the Assessing Officer.
The Mumbai ITAT ruled that MLI provisions cannot be applied to deny treaty benefits under the India–Ireland DTAA without a specific notification under Section 90(1) of the Income Tax Act.
ITAT Delhi quashes a Rs. 418 crore reassessment order for AY 2009-10 because the notice for reopening under Section 148 was not validly served on the assessee.
The Karnataka High Court upheld the exclusion of Universal Print System and BNR Udhyog as comparables in a transfer pricing case involving Robert Bosch.
The Bombay High Court allows a company to set off interest expenses against interest income, ruling that a business can be considered commenced from its preparatory stage.
Chennai ITAT ruled that the Taxation and Other Laws Act (TOLA) does not extend the deadline for assessments, citing judicial precedents. The assessment order was held to be time-barred.
ITAT Delhi deleted transfer pricing adjustments made to Sony India, ruling that the intensity adjustment is an invalid substitute for the Brightline Test and that royalty payments were commercially justified.
