Infosys BPM Limited Vs DCIT (ITAT Bangalore) Perusal of the assessment order would show that the AO did not examine the above said computation of the assessee and did not find any fault or error in the above said computation. The AO simply observes that section 14A provides that the expenditure has to be computed […]
IBM Singapore Pte Ltd. Vs DCIT (ITAT Banglore) As per the decision rendered by Hon’ble Supreme Court in the case of Engineering Analysis Centre of Excellence Pvt. Ltd., sale proceeds received by the assessee on sale of software licenses cannot be categorized as “Royalty” within the meaning of provisions of DTAA. FULL TEXT OF THE […]
DCIT Vs Heilgers Development & Construction Company Pvt. Ltd (ITAT Kolkata) The loan amounts in question treated as deemed dividend u/s 2(22)(e) by the AO were taken by the assessee-company from the three concerns on interest and since the said lending companies were compensated by interest paid by the assessee-company on the loans, the assessee-company […]
Zeenath Transport Company Vs ACIT (ITAT Bangalore) The assessee during the year made payment of Rs.10 lakhs and 20 lakhs towards membership fee and legal fund respectively to Federation of Indian Mineral Industries. The federation of Indian Mineral Industries is an association of industries i.e engaged in the business of minerals and is a non […]
Pramod Lele Vs ITO (ITAT Mumbai) 1. The expression ‘Technical Consultancy’ would only mean rendering of technical services by assessee. In our considered opinion, the expression ‘Management Consultancy’ could not be brought within the ambit of “technical consultancy”. 2. Hence, we hold that the provisions of Section 44AA(1) of the Act cannot be made applicable […]
Urban Ladder Home Décor Solutions Pvt. Ltd. Vs ACIT (ITAT Bangalore) A careful perusal of the relevant provisions of the agreement entered by the assessee with Facebook and Rocket Science Group (Mailchimp) would show that both these non-resident companies are allowing the assessee to use the facilities provided in their sites, which includes, inter alia, […]
Premier Book Company Vs Addl. CIT (ITAT Delhi) M/s Premier Book Company (Appellant) has filed the current appeal challenging the order by the Commissioner of Income Tax (Appeals) (CIT(A)) dated June 03, 2016 pertaining to Assessment Year (A.Y) 2010-11, which upheld the disallowance of depreciation on tenancy rights. The Assessing Officers disallowed the claim under […]
ACIT Vs Solvay Pharma India Ltd (ITAT Mumbai) We observe that the CBDT Circular dated 1-8-2012 (supra) in its clarification has enlarged the scope and applicability of ‘Indian Medical Council Regulation 2002’ by making it applicable to the pharmaceutical companies or allied health care sector industries. Such an enlargement of scope of MCI regulation to […]
Goodyear India Ltd. Vs NeAC (ITAT Delhi) Coming to Ground raised by the assessee against the making of adhoc disallowance amounting to Rs.3,52,33,953/- being 30% of the total expenditure of 11,74,46,510/- incurred by the assessee on advertisement and publicity. CIT DR submitted that the AE of the assessee company would certainly be benefitted by expenditure […]
ACIT Vs Farah Khan (ITAT Mumbai) During the course of assessment proceedings, it transpired that the assessee owned 6 flats / units (A3501A, A3501B, A3501C, A3601A, A3601B & A3601C) on 35th & 36th floor of a Building namely Oberoi Sky Heights situated at Lokhandwala Complex, Andheri (West), Mumbai. All the units were stated to be […]
