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Income Tax : The introduction of Section 194O in the Income Tax Act, 1961 for e-commerce transactions, has created certain overlaps with Sectio...
Income Tax : Finance Bill 2025 limits tax loss carry-forward under Section 72A to 8 years from the original assessment year. Learn about its im...
Income Tax : Explore how new tax rebate under Section 87A allows individuals to avoid tax on incomes up to Rs 12 lakh. Learn through illustrati...
Income Tax : Learn about Section 40(b) limits on partner remuneration and the introduction of Section 194T for TDS on remuneration, effective A...
Income Tax : Budget 2025 has brought significant simplification in the tax treatment of house properties, particularly for self-occupied proper...
Income Tax : CPC (TDS) reminds deductors to file TDS Statement 26Q for Q2 FY 2024-25. Late/non-filing may attract fees and affect TDS credit fo...
Income Tax : Union Cabinet has approved the new Income Tax Bill 2025, aiming to simplify and modernize India's tax system by replacing the 1961...
Income Tax : CBI registers case against 9, including Deputy Commissioner, 2 Inspectors, and 5 CAs, for sabotaging Faceless Tax Scheme; searches...
Income Tax : India's tax arrears stand at ₹47 lakh crore as of Dec 2024. CBDT & CBIC are taking steps, including asset identification, litiga...
Income Tax : India decriminalizes minor direct tax offenses to ease compliance. New measures include litigation management, compounding guideli...
Income Tax : ITAT Pune rules that late filing of Form 67 does not bar foreign tax credit under Section 90. Read about the case of Shashank Sada...
Income Tax : ITAT Ahmedabad sets aside CIT(A)'s dismissal of appeal due to non-appearance, directing fresh consideration with a proper hearing ...
Income Tax : ITAT Bangalore remits the case of Gold Palace Jewellers back to CIT(A) for fresh consideration, citing a 4-year delay and lack of ...
Income Tax : ITAT Pune confirms CIT's order under Section 263, finding errors in reassessment proceedings for Gourishankar Education Society. A...
Income Tax : ITAT Mumbai rules in favor of B. Braun Medical India, deleting ₹2 Cr addition u/s 68, citing it as an advance payment, not unexp...
Income Tax : Bhaikaka University, Gujarat, is approved for scientific research under Section 35(1)(ii) of the Income Tax Act, 1961, effective f...
Income Tax : Notification No. 14/2025 updates Form 49C submission rules for liaison offices under the Income-Tax Act. Filing deadline set to 8 ...
Income Tax : CBDT amends Income-Tax Rules, 1962, updating regulations for Infrastructure Debt Funds, including investment criteria, bond issuan...
Income Tax : CBDT authorizes data sharing with DFPD to identify PMGKAY beneficiaries. MoU to govern data confidentiality, transfer mode, and ti...
Income Tax : BILL No. 14 OF 2025 THE FINANCE BILL, 2025 (AS INTRODUCED IN LOK SABHA) THE FINANCE BILL, 2025 ARRANGEMENT OF CLAUSES ______ AS IN...
Assessee has made payments to the CDLB for supply of these workers. As long as the assessee has made payments to the CDLB for supply of labour, even when this labour may be treated as employed by the assessee for all practical purposes, the provisions of Section 194 C are clearly attracted. In such a situation, i.e. when labour hired by the assessee through CDLB is considered to be in assessee’s employment, the payments made to CDLB cannot be treated as payments for ‘any work’ , but nevertheless these payments could still be covered by the provisions of Section 194 C because these are payments made for ‘supply of labour’ which are specifically covered by Section 194 C(1).
In Re- Red Hat India Private Limited- Date of filing of the return is the relevant date to consider the applicability of the proviso to section 245R(2) of the Act, and that the filing of the return of income generates questions including the ones raised before this Authority, the jurisdiction to give a ruling in the present application has to be held to be barred. We are, therefore, constrained to reject the application as being barred by clause (i) of the proviso to section 245R(2) of the Act.
in case the assessment is set aside by the CIT(A) and setting aside become final, interest u/s. 220(2) has to be charged only after the expiry of 35 days from the date of service of demand notice pursuant to the fresh assessment order. In the case of the assessee, since the original order of assessment was confirmed by the CIT (A) but on further appeal, the Tribunal set aside the order of the CIT(A) and the issue restored to the AO, it was held that in terms of the circular, the interest u/s. 220(2) has to be charged only from the date of fresh assessment order.
The assessee, Nova Nordisk Pharma India Ltd, an Indian Company was engaged in marketing of pharmaceutical products. It was a subsidiary company of NOVA Nordisk, Singapore. One of the products (insulin in medically presentable form), was manufactured by M/s. Torrent Pharmaceuticals Limited (Torrent) and supplied to the assessee company. The raw material was supplied by a foreign company NOVA Nordisk, Denmark. Torrent pursuant to the contract, was required to sell entire output only to the assessee company in India.
The language in section 55A does not refer the ‘value of consideration’ but only uses the term ‘Fair Market value’. So the scope of the section gets con-fined to determine the fair market value of a capital asset only. Thus, considering the language of section 48 the value so deter¬mined cannot be substituted for ‘Full value of consideration’. – Section 50C states that the AO can refer to DVO u/s. 55A only if the assessee claims that the value adopted by the stamp valuation authority exceeds their fair market value or the value so adopted by stamp valuation authority has not been disputed by any authority, Court or High Court.
The Advance rulings can be sought on any question of law or fact specified in the application in relation to a transaction which has been undertaken, or is proposed to be undertaken, by the non¬resident applicant. Even a resident applicant may seek rulings regarding tax liability of a non¬resident in relation to a transaction with the resident applicant. In case of a public sector undertaking advance rulings may be sought on an issue of fact or law relating to computation of total income, pending before an Income-tax Authority or the Appellate Tribunal.
Whether adjustment should be restricted only to the international transactions or can be extended to the entire turnover of the taxpayer? 2. Are the books of accounts liable to be rejected if there is a transfer pricing adjustment? 3. Prior to 1.10.2009, is the benefit of standard deduction of-+5% under the proviso to section 92C(2) of the Act available to the taxpayer?
Whether the interest on income-tax refund is to be considered as interest income falling within Article 11(2) of the tax treaty or as interest income attributable to permanent establishment or fixed base in India falling under Article 11(5) read with Article 7 of the tax treaty? 2. whether the expression ‘attributable’ as used in Article 11(5) of the tax treaty has to be construed as equivalent / narrower to the term ‘effectively connected’ as used under Interest Article in other tax treaties with India and thereby squarely covered by the Special Bench decision of Clough Engineering Ltd.
Petitioner had filed the application for registration on 23rd September, 2006 after the 2002, Scheme had come to an end, as the scheme was applicable only upto 31 st March, 2006. The industrial park set up by them was not operational/functional by 31st March, 2006. It became operational on a subsequent date. The completion certificate for the said park issued by the Pune Municipal Corporation is dated 29th August, 2007. The petitioner cannot, therefore, claim notification under the 2002, Scheme.
On applicability of Section 50C of the Act in absence of registered document -Capital gain has to be computed on the basis of sale consideration received or accruing to the taxpayer. Even if the document was not registered, the capital gain has to be computed on the basis of the sale consideration shown and received by the taxpayer unless there was material to show that the sale consideration was understated. In this case, the document was not registered and no stamp duty had been paid. Therefore, stamp duty value cannot be adopted for the purpose of computation of capital gain and the value shown in the agreement has to be adopted as there is no material to show that the taxpayer had understated the sale consideration.
