The issue under consideration is whether the addition made u/s 40A(2)(b) in case of estimation of income without doubting expenses incurred by assessee is justified in law?
Whether A.O. is right in dismissing the claim of the assessee u/s. 54F of the Act on the ground that residential flat was not constructed after the date of transfer and they were constructed alongwith saleable flats?
Bacardi India Pvt. Ltd. Vs ACIT (ITAT Delhi) Under Sections 92B to 92F, the pre-requisite for commencing the TP exercise is to show the existence of an international transaction. The next step is to determine the price of such transaction. The third step would be to determine the ALP by applying one of the five […]
Explore ITAT Delhi’s ruling in American Express India vs DCIT. Key issues: Comparable selection, transfer pricing adjustments, corporate tax matters.
The issue under consideration is whether assessee engaged in business relating to online advertising is considered as technical services or royalty Section 9(1)(vii) of the Income Tax Act, 1961?
Expenditure incurred on Advertisement, Marketing and Promotion (AMP) for creating market intangibles including brand value in favour of Associated Enterprises was not considered as an international transaction as mere use of brand name or logo owned by the AEs by assessee would not automatically lead to influence that any expenses that assessee incurred towards AMP was only to enhance the brand and there was no cogent material to treat the incurring of AMP expenses as international transactions.
Aesseal India Pvt. Ltd. Vs ITO (ITAT Pune) The only issue that arises for our consideration is whether the loss arising out of reinstatement of the ECB loan as on date of balance sheet can be added to the actual cost of asset for the purpose of determining the actual cost u/s 43A of the […]
Jai Gopal Sondhi Vs ITO (ITAT Delhi) We note that although the Assessing Officer has levied penalty in all the four cases for non-compliance of statutory notices, all the same he has proceeded to frame the assessment order u/s 143(3) of the Act. We also note that the CIT(A), while dismissing the assessees’ appeals has […]
DCIT Vs Paresh K. Shah (ITAT Mumbai) Conclusion: Since the date of initiation of search u/s 132 for the purpose of an assessment u/s 153C had to be construed as the date of receiving the books of account by the AO having jurisdiction over such other person, from the A.O. of the searched person, the […]
The issue under consideration is whether AO is correct in making addition for royalty on account of alleged royalty taxable under section 9 (l)(vi) of the Income Tax Act, 1961 read with Article 12(3) of India Switzerland Double Taxation Avoidance Agreement (DTAA)?
