VDB Infra vs. ITO: ITAT Bangalore case involves TDS deduction dispute resulting in penalty deletion under Section 270A(9)(a) by the tribunal.
In the case of Dassault Systems Simulia Corp Vs DCIT, ITAT Chennai rules that Section 155(14) cannot limit TDS credit if income is disclosed in ITR, allowing full credit as per Form 26AS.
Analysis of ITAT Delhi’s ruling: Sale of software products not taxable as royalty under India-Japan DTAA, citing Engineering Analysis case. Details of DCIT Vs Dassault Systems Biovia K.K.
ITAT Chennai directs condonation of delay in appeal filing due to valid reasons including 56 pre-COVID days, advancing substantial justice.
Read about the ITAT Kolkata’s decision to uphold the addition of share capital and premium under Section 68 for Invorex Trading Pvt. Ltd. vs ITO. Get insights into the case and its implications.
ITAT Delhi held that expense towards management and marketing support service paid to foreign company is not taxable under Fee for Technical Service (FTS) under India-Netherlands Double Taxation Avoidance Agreement (DTAA) and hence TDS not deductible u/s. 195 of the Income Tax Act.
ITAT Mumbai held that the expenses excluded from the export turnover have to be excluded from the total turnover as well while computing deduction u/s 10A of the Income Tax Act.
ITAT Guwahati held that the exemption of 10(26) of the Income Tax Act is available to the individual members of the Scheduled Tribe and that this benefit cannot be extended to a firm which has been recognized as a separate assessable person under the Income Tax Act.
ITAT Mumbai held that as there is complete uniformity in not charging interest from AEs and Non-AEs for delay in realization of export proceeds, addition of notional interest in respect of transactions with AEs in the course of transfer pricing proceedings unwarranted.
ITAT Delhi held that the reopening of assessment had been initiated by mere surmise and conjecture without having any cogent material to form a reasonable belief that income of the assessee had escaped assessment within the meaning of section 147 of the Income Tax Act.
