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Income Tax : Details of the Lok Sabha Select Committee's sittings on March 6-7, 2025, to examine the Income-Tax Bill, 2025, with oral evidence ...
Income Tax : CBDT updates income tax rules and forms for business and securitization trusts. Notification 17/2025 amends Rules 12CA & 12CC, imp...
Income Tax : Key updates on income tax deduction from salaries under Section 192 for FY 2024-25, including amendments, surcharge rates, and new...
Income Tax : CBDT extends the due date for filing Form 56F under Section 10AA(8) and 10A(5) of the Income-tax Act, 1961, to March 31, 2025, for...
Income Tax : The Central Government notifies Punjab RERA for tax exemption under Section 10(46A) of the Income-tax Act, effective from the 2024...
It was held by the Third Member that section 147 applies both to section 143(1) as well as section 143(3) and, therefore, except to the extent that a reassessment notice issued u/s 148 in a case where the original assessment was made u/s 143(1) cannot be challenged on the ground of a mere change of opinion,
With regard to the adjustment of refunds against the outstanding demands, various communications have been issued in the past. A brief reference of the same is as under:
In the instant case, the contributors, namely, the members of the assessee made contributions, which have been kept in fixed deposit with third party banks and those third party banks have contributed to the members fund. Accordingly, the members fund have been expanded not by the contributors/members, but by a third party.
New website of income tax e-filing can’t be loaded on many computers where the Windows XP is installed. The error occurs with message Invalid Certificate or with some other wordings in different browsers.
Amalgamation does not come within the scope of ‘transfer’ as defined in Section 2(47) of the Act and such being the view taken not only by this court, but Madras High Court and also the Supreme Court, there is no question of holding that the assessee disentitles the benefit of Section 80-I of the Act.
The profit margin from the international transaction with the A.E. has to be seen in relation to the uncontrolled transaction with the independent parties. What is to be compared is the international transactions of the assessee with its related parties and not for its entire transaction with non-related parties also. Therefore, ALP has to be seen only with regard to international transaction with A.Es and not on the entire turnover/sales.
A plain reading of provisions of section 35DDA, it is clear that compliance with the conditions of rule 2BA is mandatory only to avail exemption under section 10(10C) by the employees but said rule is not relevant to deduction under section 35DDA.
For the purpose of Section 40(b)(v) read with Explanation there cannot be separate method of accounting for ascertaining net profit and/or book-profit. In other words, according to the said Explanation ‘book profit’ means the net profit as shown in the profit and loss account including income from other sources not the profit computed under the head profit and gains of business or profession.
Working given by the TPO shows that it is earning 7% commission, whereas as per the industry policy as decided by the AAAI the service on media agency earns commission of 2.5%. On that reason also, since it is an extreme case of earning 7% commission (in our view it is wrongly considered), on the principles that the extreme profit companies are to be excluded, this company cannot be considered as comparable for the purpose of arriving at the average mean.
Learned counsel was specifically asked whether he is in a position to produce, or has produced at any stage, evidences for services having been rendered by the persons, who have been paid the commission. While learned Counsel referred to the fact that these incomes are duly disclosed in the hands of the recipient that the same commission was allowed deduction in the other years, he was not in a position to produce any evidence for services rendered, nor such evidence was produced before the authorities below.