Nike India Private Limited Vs ACIT (ITAT Bengalore) There is no dispute that the parent company Nike Inc., has introduced new products and the samples are supplied to third party distributors in order to create awareness of new products amongst the public. The assessee herein is merely an intermediary between M/s Nike Inc and the […]
Red Hat India Private Limited Vs DCIT (ITAT Mumbai) Upon careful consideration we find that assessee has been following consistent system of revenue recognition. The assessee is inter alia engaged in the business of marketing, promotion and sale of ‘Red Hat subscriptions’ to customers in Indian sub-continent to avail support services that are for the […]
Hyundai Construction Equipment India Private Ltd. Vs ACIT (ITAT Pune) Ground no.8 of the appeal is against making transfer pricing adjustment on entity level rather than restricting it to the AE transactions. The TPO computed the transfer pricing addition by considering revenues from Manufacturing segment‘ in totality at the entity level The DRP did not […]
Vinay Kumar Dhingra (HUF) Vs ITO (ITAT Delhi) Contention of Assessee: 1. The assessee fulfills all conditions specified u/s. 10(38) 2. Though the purchase of securities are off market, the sale of shares was made online on which STT has been duly paid. 3. The shares were held for approximately 18 to 20 months 4. […]
Reliance Globalcom Limited Vs DCIT (ITAT Mumbai) Conclusion: Standby Maintenance Charges received by assessee from TCL could not be assessed as FTS and was its “business income‟ that was taxable only to the extent of its reference to the “business connection” in India. Turnover (receipts) of Standby Maintenance Charges from TCL i.e attributable to the […]
Delhi Police Welfare and Recreational Club Fund vs. CIT (ITAT Delhi) We have gone through the record in the light of the submissions made on either side. Insofar as the nature of activity of promotion of welfare and recreational activities of the police personnel, by its nature, is concerned, Ld. CIT(E) does not dispute whether […]
Tata Motors Ltd. Vs DCIT (ITAT Mumbai) M/s. Tata Motors Ltd. (Appellant) filed an appeal against the order of Commissioner of Income Tax (Appeals), computing set-off of Minimum Alternate Tax (MAT) credit under Section 115JAA of the Income Tax Act, 1961 (the IT Act) excluding surcharge and cess resulting in short grant of MAT credit […]
Shree Digamber Jain Shiksha Samiti Vs CIT (E) (ITAT Agra) ITAT considered the rival contention of the parties and perused the material available on record, including the judgments cited at bar during the course of hearing by both the parties. As is evident from the paper book filed before us that the assessee has provided […]
ITAT Mumbai expressed doubts on correctness of decisions of coordinate benches on dividend distribution tax (DDT) rate being restricted by treaty provision dealing with taxation of dividends in the hands of shareholders.
Karnataka Judicial Officers Credit Co-operative Society Ltd. Vs ITO (ITAT Bangalore) The next issue relates to the deduction claimed by the assessee u/s.80P(2)(d) of the Act in respect of interest income. Identical issue has been considered by the co-ordinate bench in the case of Karkala Co-op Bank Ltd (supra). For the sake of convenience, we […]
