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Income Tax : The Income-tax Act, 2025 continues the old specified professions framework without addressing longstanding classification issues. ...
Income Tax : The Supreme Court dismissed the Revenue's review petitions and reiterated that payments for off-the-shelf software do not constitu...
Income Tax : A detailed overview of limitation periods prescribed under the Income-tax Act reveals how missing statutory deadlines can lead to ...
Income Tax : Budget 2026 has extended the due dates for ITR-3, ITR-4, and revised returns, offering taxpayers greater flexibility. Understandin...
Income Tax : Relocating to Sikkim does not automatically exempt you from income tax. This article explains who qualifies under Section 10(26AAA...
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 Tribunal held that an incomplete document recovered from an employee's laptop could not justify an addition under Section 69 w...
Income Tax : The ITAT held that once registration under Section 12AB was ultimately granted on the basis of the original application, the doctr...
Income Tax : The ITAT Chennai ruled that funds received by a Chartered Accountant for remitting clients' taxes could not be treated as unexplai...
Income Tax : ITAT Mumbai held that appellate forums can entertain additional claims even without a revised return. The matter was remanded to t...
Income Tax : The Telangana High Court held that recovery proceedings under Section 226(3) cannot automatically extend to a daughter's bank acco...
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...
CBI on Sunday arrested an Income Tax Commissioner from Nagpur and his wife for allegedly amassing assets disproportionate to their known source of income to the tune of Rs 4 crore. While IT Commissioner Ajay Kumar Singh was arrested from Mumbai airport by CBI sleuths, his wife Mrunalika Singh was His wife Mrinalika was picked up by the agency from their residence at Seminary Hills for abetting corruption. CBI officials had been on the trail of his assets over the last few days, after a tip-off.
Atul Mohan Bindal – assessee filed return of his income for Assessment Year 2002-03 on August 8, 2002 declaring his total income Rs.1,98,50,021/ -. In the assessment proceedings u/s 143, a notice alongwith questionnaire was issued to him by the Assessing Officer on November 29, 2002. Pursuant thereto, assessee attended the assessment proceedings and furnished the requisite details. During the assessment proceedings, it transpired that assessee worked with M/s DHL International( S) PTE Ltd.,Sing
. The undisputed facts are that the assessee had plant and machinery already existing prior to the receipt of finance from Wipro Finance Ltd. It is apparent from the chart of payment referred to by the learned AR of the assessee. This clearly indicates that the loan was not given directly or indirectly for the purpose of purchasing plant and machinery.
The issue to be considered is whether the profit earned by the assessee from the activity of recruitment and training of personnel and supplying the data thereof to its parent company in US is eligible for deduction under sec.lOA or not read with the Board’s Circular dated 26.9.2000. In this connection, it would be worthwhile to consider first the role of the circulars issued by the Board.
Where income of the assessee having been determined by resorting to estimation, there is no scope for any further disallowance either in terms of section 40(a)(ia)/40A(3) or otherwise.
From now on, when you get a gift in kind, valued at more than Rs. 50,000, from your parents or other relatives, make sure you have a sworn affidavit declaring the donor your kin.The Central Board of Direct Taxes has ruled that any such gift will be taxable for the donee unless it is from relatives or given during occasions such as marriage or by way of inheritance.
In Asia Satellite 85 ITD 478 the Tribunal held that the said receipts were taxable as ‘royalty’ having been paid in respect of a “process”. However, in PanAmSat 9 SOT 100 it was held that as in the term “royalty” in Art. 12 of the India-USA DTAA there was a ‘comma’ after the words “secret formula or process”, it was only a ‘secret process’ which would qualify as royalty and not what was provided by the assessee. To resolve the conflict, the issue was referred to the Special Bench. HELD, reversing PanAmSat:
Even if it is accepted that by a transfer of shares u/s 2(47), there is a transfer in the right to use the capital assets of the company, still s. 170 is not attracted because there is no “transfer of business”. A company is a juristic person and owns the business. The share holders are not the owners of the company. By a transfer of the shares, there is no transfer so far as the company is concerned.
The Assessing officer initiated proceedings for alleged violation of section 269SS of the Act in as much as the assessee accepted share application money being Rs.20,000/- in cash. Thereafter, penalty was imposed. On appeal, CIT(A) upheld the stand of the assessee that the amount received
The Central Board of Direct Taxes had issued Circular No. 23 (hereinafter called “the Circular”) on 23rd July 1969 regarding taxability of income accruing or arising through, or from, business connection in India to a non-resident, under section 9 of the Income-tax Act, 1961. 2. It is noticed that interpretation of the Circular by some of the taxpayers to claim relief is not in accordance with the provisions of section 9 of the Income-tax Act, 1961 or the intention behind the issuance of the Circular.
