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Income Tax : The article outlines practical methods through which business owners and professionals can legally minimise their tax burden. It h...
Income Tax : Section 54 grants exemption on long-term capital gains from the sale of a residential house because the proceeds are reinvested in...
Income Tax : The Income-tax Act mandates e-payment of direct taxes for companies and taxpayers covered under Section 44AB, while others may opt...
Income Tax : Form 16 and Form 16A serve distinct purposes under the TDS framework, with Form 16 relating to salary income and Form 16A covering...
Income Tax : Permanent Account Number (PAN) serves as a unique identifier enabling the Income-tax Department to track tax payments, returns, TD...
Income Tax : The CBI apprehended an Income Tax Office Superintendent in Odisha after he was allegedly caught accepting a bribe for deleting a d...
Income Tax : The Income Tax Appellate Tribunal has proposed a priority disposal mechanism for appeals filed up to and including 2022 in respons...
Income Tax : A representation has urged CBDT to merge TDS return codes 1023 and 1024, arguing that both apply to the same contract payments wit...
Income Tax : Association requested CBDT to rationalize CASS 2026 case selection considering the administrative burden caused by implementation ...
Income Tax : KSCAA requested the CBDT to release e-filing utilities and schemas for AY 2026-27 without delay, stating that pending utilities ar...
Income Tax : The Rajasthan High Court held that an order restoring appeals through review proceedings is not separately appealable under the Be...
Income Tax : The Tribunal found that the authorities below failed to properly apply the principles governing section 80P deductions relating to...
Income Tax : The ruling emphasizes that undisclosed business receipts and stock arising from an existing business cannot automatically be chara...
Income Tax : Addition of ₹90 lakh made under section 69A towards alleged cash payment for purchase of property as well as the addition made u...
Income Tax : The Tribunal noted that donations to Swachh Bharat Kosh and Clean Ganga Fund made towards CSR obligations are specifically exclude...
Income Tax : The CBDT has identified specific categories of taxpayers whose returns will be compulsorily selected for complete scrutiny during ...
Income Tax : The Ordinance exempts interest income and capital gains arising from Government securities for Foreign Institutional Investors and...
Income Tax : The Central Government has specified infrastructure sub-sectors from the Updated Harmonised Master List as eligible businesses und...
Income Tax : CBDT has granted scientific research approval under the Income-tax Act, 2025, enabling eligible donations to qualify for tax benef...
Income Tax : CBDT has granted scientific research approval under the Income-tax Act, 2025, allowing eligible donations to qualify for tax benef...
It is clear from this proviso that where assessee transfers his capital asset after 30th September of the financial year he gets an opportunity to make an investment of Rs.50 lakhs each in two different financial years and is able to claim exemption upto Rs.1 Crore u/s 54EC of the Act. Since the language of the proviso is clear and unambiguous, we have no hesitation in holding that the assessee is entitled to get exemption upto Rs.1 Crore in this case. Since the wording of the proviso to section 54EC is clear, the benefits which are available to the assessee cannot be denied. In view of above, it is hereby held that the assessee is entitled for exemption of Rs.1 crore as six months’ period for investment in eligible investments involved is two financial years.
Although interest paid to the head office of the assessee bank by its Indian branch which constitutes its PE in India is not deductible as expenditure under the domestic law being payment to self, the same is deductible while determining the profit attributable to the PE which is taxable in India as per the provisions of article 7(2) & 7(3) of the Indo¬Japanese treaty read with paragraph 8 of the protocol which are more beneficial to the assessee.
The assessee has not claimed depreciation on goodwill it acquired commercial rights to sell products under the trade name and paid consideration in dispute for acquiring marketing and territorial rights to sell through dealers and distributors i.e. the network created by the seller for sale in India. Under the agreement. It become entitled to use of infrastructure developed by the seller. Rights were acquired since 1.4.1998 and these rights have all along been treated as an asset entitled to depreciation and depreciation was actually allowed in the past.
The decision of Bombay High Court in the case of Kalpataru Colours & Chemicals (supra) has been set aside and reversed by the Supreme Court in their decision dated 8.02.2012 in the case of Topman Exports Vs. Commissioner of Income Tax, Mumbai (C.A. No.1699/2012) and other cases. In this decision, it has been held that the DEPB credit falls under Clause (iiib) of Section 28 of the Act whereas the premium received thereon on transfer will represent profits chargeable under Section Clause (iiid) and the deduction under Section 80HHC has to be computed accordingly. It was held that only 90% of the “profits” can be excluded by applying Explanation (baa) below Section 80HHC.
Section 14A were introduced with prospective effect from the assessment year 2007-08 onwards. However, sub-section (2) of Section 14A remained an empty shell until the introduction of Rule 8D on 24.03.2008 which gave content to the expression “such method as may be prescribed” appearing in Section 14A(2) of the said Act.
In response to the 2011 update of the UN Model Convention which was launched on 15.3.2012, the CBDT has addressed a letter dated 12th March 2012 in which it has registered its objections to the provisions in the UN Model Convention. In particular, the CBDT has stated:
Honorable Finance Minister, Sh. Pranab Mukherjee will inaugurate the Direct Taxes Regional Training Institute complex, Bangalore on 8th April 2012.
(1) An individual or HUF must file the return of income electronically for the previous year 2011-12 / Assessment year 2012-13 and subsequent previous year if his/its total income exceeds Rs. 10 lakhs. (2) A resident Individual or a resident HUF must file the return of income electronically for the previous year 2011-12 / Assessment year 2012-13 and subsequent previous year, if he/it has: (a) assets (including financial interest in any entity) located outside India; or (b) signing authority in any account located outside India.
The due date for submission of ITR-V is 120 days from the date of upload of e-return. This is to inform you that in this F.Y. 2011-12, we have received 16,433,683 e-filed returns having the growth of 81.58%.
Recently I have faced a very interesting situation. I have to file ITR of one of my client online. My client is a HUF and his turnover is more then Tax Audit limit so as per Recent Income tax circular, I was required to file his Income Tax Return online. While filling ITR I needed his date of birth or say incorporation date so I checked his PAN card to know the same as per Income Tax Record, when I checked the PAN card the date of birth mentioned on it was for my surprise written as ,ANCESTRAL,.