Modern Papers Vs ITO (ITAT Delhi) During the assessment proceedings claim of assessee could be considered by way of a simple letter without filing any revised return The assessee is engaged in the business of Agro Chemicals and set up a manufacturing unit in the State of Jammu & Kashmir, which is notified area, entitling […]
Depreciation expense to be considered as operating & revenue generated from non-routine business operations to be considered as non-operating in nature in transfer pricing calculations for taxpayers as well as comparable companies.
Megger India Pvt. Ltd. Vs DCIT (ITAT Mumbai) We find that the authorities below have erred in not appreciating the documents submitted by the assessee. While the TPO has not adopted any of the methods prescribed for benchmarking the international transaction, he has erred in applying the benefit test. On the other hand the assessing […]
Common maintenance charges received from tenants of property were towards maintenance and promotion of common area and the same were business receipts liable to be assessed under the head ‘Income from business’.
EIT Services India Pvt. Ltd. Vs JCIT (ITAT Bangalore) It has been submitted by Ld.AR that working capital and risk adjustment was denied to assessee on the ground that assessee failed to demonstrate such differences could have any impact on assessee’s profit. It has been submitted by Ld.AR that the submissions advanced by assessee demonstrating […]
In present facts of the case, the Hon’ble Tribunal relied upon the previous Judgments passed in the assesse own case and have observed that agents of the assessee did not have the necessary authority to conclude the contracts of the assessee and, on that premise, it was held that there is no agency PE of assessee in India and therefore Assessee was not taxable in India.
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 […]
