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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...
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.
