Appellant contended that such contribution is made for empowerment of women however, the CIT(A) in its order observed that although the expenditure was for a noble cause, it has no nexus contribution made and the income generated for the business of the Appellant company under Section 37 of the IT Ac
International Bakery Products Ltd. Vs ACIT (ITAT Chennai) Prior period item whether expenses or income is an item of expense deductible or item of income, always comes below the line in the profit & loss account. That means, for all practical purposes, the net profit as per books of account for the relevant period is […]
Trigo SAS Vs DCIT (ITAT Pune) Assessee has merely transferred the right to use copyrighted software ANTIFOG and that it had not transferred the copyright itself to Trigo India. TRIGO India was authorized to have access to and make use of the copyrighted software ANTIFOG. In the Software License Agreement entered into, it is evident […]
Tech Mahindra Business Services Limited Vs DCIT (ITAT Mumbai) During the course of assessment proceedings, the assessee was asked to furnish the break-up of foreign exchange gain credited in the profit and loss account amounting to Rs.13,31,38,000/- for which deduction u/s.10A of the Act was claimed by the assessee. The assessee was also asked to […]
DSIIDC Ltd. Vs PCIT (ITAT Delhi) It is pertinent to note that the Assessing Officer has raised only a query before completion of assessment u/s 143 (3) relating to claim of 80IA(4). However, the Assessing Officer has not given any cogent finding. Thus, the observation of the Principal Commissioner of Income Tax that the assessment […]
Green Park Estate Pvt. Ltd. Vs ACIT (ITAT Delhi) A perusal of the reasons recorded in the case of the assessee as well as in the case of M/s Green Valley Tower Ltd. are identical on the issue of alleged interest paid on post dated cheuqes. We have also gone through the paper book containing […]
ITAT find that order u/s 263 passed by PCIT dwelled into the issue of re-computation of capital gains which is beyond the mandate of limited scrutiny issued by CBDT. Hence, directions of PCIT are beyond selection criteria of scope of scrutiny for instant year cannot be held to be legally valid.
ITAT held that in case A comparable having an extraordinary financial event of Merger and Acquisition (M& A) during the year the same cannot be considered as functionally comparable for transfer pricing (TP) comparability analysis.
Mobileum Inc Vs DCIT (ITAT Mumbai) since transactions between the assessee and its AE have been found at arm’s length prices no further income chargeable to tax in India can be said to be attributable for the PE of the assessee. FULL TEXT OF THE ORDER OF ITAT MUMBAI This appeal by the Assessee is […]
DCIT Vs Singhania Buildcon Pvt. Ltd. (ITAT Raipur) 1. AO has not made any attempt to rebut the claim of the assessee. The confirmations were filed by the assessee to support the factual position. The assessee has placed the facts which are apparent in nature for which no rebuttal has been done. 2. The Hon’ble […]
