Discover ITAT Bangalore’s decision on Aptean India Pvt. Ltd.’s appeal against assessment order for AY 2013-14 regarding education cess deduction.
Eit Services India Pvt. Ltd. Vs ACIT (ITAT Bangalore) According to the Assessee, it was on the basis of professional opinion, under the belief that the issues that were sought to be agitated before the CIT(A) against the order of assessment dated 30.12.2008 could be agitated before the AO in the proceedings pursuant to the […]
Income earned by assessee from shipping operations in India was not taxable in India by virtue of Article 24 of India Singapore DTAA as the conditions stipulated under Article 24 were not satisfied and the benefit of Article 8 of India Singapore DTAA was applicable and as per which shipping income of a resident of Singapore was taxable only in Singapore but not in India.
ACIT Vs Him Urja Pvt. Ltd. (ITAT Delhi) The assessee has also submitted before the Ld. CIT(A) that as there was no exempt income earned by assessee during the relevant previous year, no disallowance under section 14A could be made. The assessee relied upon Judgment of the Hon’ble Delhi High Court in the case of […]
DCIT Vs Shri Rajamannar Thennati (ITAT Ahmedabad) The assessee was employed with Sun Pharma Advance Research Co. Ltd. as whole time director of the company with maximum salary of Rs. 3.5 crores as per the resolution passed in the annual general meeting of the company dated 31st July, 2012. Since there was limit for payment […]
No transfer pricing addition in respect of international transaction of payment of Regional Service Charges pertaining to five intra-group services could be made because even if presume that the comparable uncontrolled transaction was at zero mark-up, still the value of the international transaction was within the notified tolerance range.
Paschimanchal Vidhyut Vitran Nigam Ltd. Vs DCIT (ITAT Delhi) AO noticed that assessee had made assessment of electricity duty of Rs. 5,52,98,00,000/- of which Rs. 3,44,22,00,000/- was adjusted from the subsidy and the balance amount of Rs.2,08,76,00,000/-was not paid by the assessee before filing the return of income. Assessee was asked to justify as to […]
DCIT Vs Rajamannar Thennati (ITAT Ahmedabad) The assessee was employed with Sun Pharma Advance Research Co. Ltd. as whole time director of the company with maximum salary of Rs. 3.5 crores as per the resolution passed in the annual general meeting of the company dated 31st July, 2012. Since there was limit for payment of […]
The issue under consideration is whether the disallowance made by AO u/s 14A is justified in law? In view of the fact that no proper satisfaction was recorded, in our considered opinion, the Assessing Officer did not acquire any valid jurisdiction for computing disallowance u/s 14A.
The issue under consideration is whether DRP is correct in considering the Liaison Office (LO) and Land Earth Station (‘LES’) constitutes a permanent establishment (PE) in India?
