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)?
The issue under consideration is whether the addition made by AO u/s 14A read with rule 8D is justified in law? Respectfully following the precedent, ITAT set-aside the impugned order on this score and order to delete the disallowance.
Surana Enterprises Vs ITO (ITAT Delhi) The issue under consideration is whether the addition made by AO u/s 69C by considering the purchases as Bogus Purchase is justified in law? ITAT states that, in present case, the assessee has shown sales of the goods, or otherwise the goods are lying in the closing stock. If […]
National Aluminium Company Ltd. Vs ACIT (ITAT Cuttack) The issue under consideration is whether disallowance u/s 14A without following calculation method mentioned under rule 8D is justified in law?
Issue was as regards imposition of penalty under section 271(1)(b) for non-compliance by assessee with respect to statutory notices issued under section 142(1), when assessment was completed under section 143(3).
