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Income Tax : Learn about TDS on payments to non-residents, including business connection rules, royalty provisions, and significant economic pr...
Income Tax : Discover key changes in the Income Tax Bill 2025, including enhanced rebates, simplified trust provisions, and extended registrati...
Income Tax : Section 194T mandates 10% TDS on partner payments exceeding ₹20,000 annually, effective April 1, 2025. Learn its impact, complia...
Income Tax : Understand income tax rules for business & profession in India. Covers business, profession, vocation, occupation, and deduction g...
Income Tax : In the realm of taxation, income is classified into various categories, with one of the most significant being Income from Busines...
Income Tax : India's direct tax collections for FY 2024-25 show a 13.13% net growth, with gross collections up by 16.15% and significant gains ...
Income Tax : CBDT issues clarification on Circular 01/2025, stating it applies only to the Principal Purpose Test in certain DTAAs and does not...
Income Tax : Corporate tax collections increased post-rate cuts. No specific tax incentives for MNCs, but new measures aim to support electroni...
Income Tax : The Income Tax Bill 2025 aims to simplify tax laws with no major policy changes. It enhances clarity, reduces ambiguities, and ali...
Income Tax : The Finance Bill 2025 projects a 12.65% rise in income tax collections despite tax cuts, with estimated receipts of ₹25.20 lakh ...
Income Tax : The Assessee is aggrieved by the information received pursuant to application under Right to Information Act, 2015, whereby the As...
Income Tax : ITAT Mumbai held that exercising revisionary jurisdiction under section 263 of the Income Tax Act by PCIT on the basis of factual ...
Income Tax : ITAT Ahmedabad held that assessment order passed u/s. 143(3) is neither erroneous nor prejudicial to the interest of revenue. Henc...
Income Tax : During pendency of the assessment proceedings, respondent No.1 filed application u/s. 245C(1) before the Income Tax Settlement Com...
Income Tax : Bombay High Court held that exercising extraordinary jurisdiction under Article 226 of the Constitution of India not justified as ...
Income Tax : Finance Ministry specifies Power Finance Corporation Ltd.'s ten-year zero coupon bond with Rs. 49,546 discount, for Income-tax Act...
Income Tax : Learn about high-risk transaction case verification, assessment, and proceedings under Sections 148/148A on the Insight and ITBA p...
Income Tax : Learn about high-risk CRIU/VRU case verification, assessment, and proceedings under Sections 148/148A on the Insight and ITBA port...
Income Tax : Learn about suspected benami, undisclosed foreign assets, and TDS compliance cases assigned under Risk Management Strategy via the...
Income Tax : The IT Dept. has flagged high-risk non-filers for AY 2019-22 on the Insight Portal under RMS Cycle 5. Assessing Officers can revie...
Dive into the case of Demag Cranes & Components vs. DCIT, exploring provisions of 10B(1)(e)(iii) of the Income Tax Rules and TP adjustments.
Procedure for Filing Settlement Application Settlement application is to be filed only in the prescribed Form No.34-B notified under the Income Tax Rules, 1962. The form has to be signed by the applicant himself. The Form has to be properly filled up. An incomplete Form is liable to be rejected. In order to be admitted by the Commission, full amount of tax is to be paid alongwith interest payable till the date of admission The application can be made personally or by post. The applicant or his authorized representative can make application in person. Application can also be sent by registered post addressed to the Secretary. However in case of a postal application, the date of receipt in the Commission shall be treated as date of application.
1. What is meant by Settlement in respect of tax disputes? How is it different from the appellate process? Settlement of disputes relating to Income Tax and Wealth Tax is based on the objective of dispute resolution Alternate. It is in the nature of mediation or arbitration. The Settlement orders passed by the Income Tax Settlement Commission are final and conclusive in nature.
1. Time-Limit – DTC has kept the time limit for passing final settlement orders under Section 245D(4) at 18 months, as in the IT Act, 1961, however has increased various internal time-limits as under:
The issue of transfer price affects various types of taxes. Under Custom Laws, special valuation branch examines the validity of the transaction value between associated enterprises. In Service Tax law, service tax has been imposed on import of service through reverse charge method and it is expected that Service Tax department would like to examine the value of services imported (or exported) to associated enterprises. In Income Tax, it is transfer price mechanism which takes care of this situation.
Though there are nine grounds raised by assessee there are only two issues involved in this appeal. One issue in ground no.3 is relating to confirmation of dis allowance of Rs. 25,000/- made by AO and further enhancement of dis allowance by Rs. 1,56,609/- u/s 14A of the IT Act.
Finance Minister Pranab Mukherjee today said stress has to be put on direct tax collection as part of the country’s revenue generation exercise. While the amount of direct tax collected last year was Rs 5,96,000 crore, the indirect tax collection was Rs 3,76,000 crore, the minister said. Inaugurating a new income tax building here in this industrial town, Mukherjee said that a recruitment drive in the income tax sector would be undertaken shortly.
The existing role and functions of CIT(CO) had been defined with reference to erstwhile Regional Computer Centres (RCCs) and they were also acting as Nodal points for distribution of hardware etc. in the initial phases of Computerisation in the Department. Post consolidation of Regional Data Bases stabilized Taxnet and PDC, BCP & DR Sites becoming fully operational, redefining and recasting the role and functions of CIT (CO) had become imperative. Deliberations in the Directorate were ongoing to recast the same so as to align it in the new environment.
Nandi Steels Limited Vs The ACIT (ITAT Bangalore)- It is not in dispute that the land, building and bore well sold by the assessee were used by the assessee for its business purposes. It is also not disputed that these assets were fixed assets of the assessee. The only argument of the assessee has been that they have direct nexus with the business carried on by the assessee and therefore, are business assets and any gains from the sale of such assets would also have the character of business income.
The core issue that we are really required to adjudicate in this appeal is whether or not, on the facts and circumstances of this case, the assessee can be said to have a permanent establishment (PE)1 in India, and, if it is held that the assessee indeed has a permanent establishment in India how much profits can be taxed as being attributable to such a permanent establishment.
