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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...
11. Section 244A has been inserted on the statute by the Direct Tax Laws (Amendment) Act, 1989 we f. 1st day of April 1989 and it has been inserted in lieu of Section 214 243 and 244. Sub-section (1) of Section 244A provides for granting of refund by the Revenue to the assessee in the cases where payment of advance tax and TDS exceeds the tax liability In the present case, there is no dispute so as for the entitlement of assessee to get refund, but the controversy is regarding the period which is to be excluded as per provisions of Section 244A (2).
20. We have heard both the parties and have carefully gone through the orders of the authorities below. Explanation 2 below sub section (2) of section 80IB provides that where in the case of an industrial undertaking, any machinery or plant or any part thereof previously used for any purpose is transferred to a new business and the total value of the machinery or plant or part so transferred does not exceed 20 per cent of the total value of the machinery or plant used in the business, then for the purpose of clause (ii) of sub-section 2 of section 80IB,
7. In the aforestated background now we may advert to the factual position in the instant case. In this case, after the processing of return under section 143(1) the Assessing Officer recorded reasons on 8-2-2006 to initiated proceedings under section 147/148 as under: ” the assessee filed return of income for the above noted assessment year declaring total income at Rs. Nil
Small and medium-sized firms that undertake the bulk of actual manufacturing for large companies may now have to forgo a part of their revenues upfront as tax deducted at source under new rules being considered by the government to widen the tax net and make revenue collections more efficient. The government is proposing changes to […]
As India’s peak income-tax rates begin to hurt, the number of high networth individuals (HNI) seeking to take residence outside the country is going up sharply, according to leading wealth managers, tax consultants and immigration lawyers whom ET spoke to. Peak income tax rates in India are as high as 33% as against 0% in […]
(1) S. 292BB, inserted by the F.A. 2008 w.e.f. 01.04.2008, creates a legal fiction and takes away the right of an assessee to claim that in case of invalid notice the whole proceedings taken pursuant to that notice would be void ab initio and will have no legal consequences; (2) However, the rule of interpretation of statutes is that a provision creating a new disability or obligation and imposing a new duty in respect of completed transactions cannot be construed to be retrospective;
The nature of the expenditure treated as a deferred revenue expenditure in the books needs to be properly analysed before taking a view on its allowbaility or otherwise under the provisions of the Act,where such expenditure results in the creation of any capital asset – tangible or intangible – a case can be made out to treat the same as a capital expenditure with corresponding allowability of depreciation in accordance with law,in cases where the nature of the revenue expenditure is such that the same can be clearly and unambiguously identified over specified future time periods (e.g. discount on issue of debentures) akin to prepaid expenses, the same would be allowable over the period to which these relate proportionately, applying the matching principle.
25. On the basis of above material, it is not possible to hold that assessee was carrying on mere repair of transformers and not any manufacturing activity. Assessee’s claim that it is manufacturing electromechanical parts and accessories like winding coils, insulation material etc. etc. from different material is clearly established on record. No dispute had been raised that above items manufactured by the assessee
8. The term technical service has come for the consideration before the Hon’ble Delhi High Court in the case of Estel Communications Pvt. Ltd. (supra). In the said case, the assessee was providing internet bandwidth for providing access to its subscribers. The main server, based on which the internet services were provided were located in USA. In that case, the Assessing Officer was of the opinion
35. The intention behind enacting provisions of section 2(22)(e) are that closely held companies (i.e. companies in which public are not substantially interested), which are controlled by a group of members, even though the company has accumulated profits would not distribute such profit as dividend because if so distributed the dividend income would became taxable in the hands of the shareholders.
