Convergys Customer Management Group Inc. Vs ADIT (ITAT Delhi) The assessee made payment for link charges to telecom service providers in the USA and cross-charged the portion of the cost incurred by it in connection with the India half link to CIS, which was accordingly reimbursed by CIS to assessee. The assessee has merely procured […]
Omni Active Health Technologies Ltd Vs ACIT (ITAT Mumbai) The issue under consideration is whether the deduction u/s 35(2AB) towards research and development expenditure claimed by assessee is justified in law? In present case, the assessee claimed deduction u/s 35(2AB) being 200% of amount incurred towards scientific research. The perusal of approvals from DSIR in […]
Month is to be interpreted as period of 30 days and not British calendar for levying additional interest u/s 201(1A) for late payment of TDS?
AMP expenditure of assessee did not have a direct bearing on the promotion of brands of its AEs as the issue stood decided in favour of assessee by the decision of the Tribunal in assessee’s own case for the preceding assessment years i.e., A.Y. 2007-08 and 2008-09.
Income from cloud hosting services had erroneously held as royalty within the meaning of explanation (2) to section 9(1)(vi) as well as Article 12(3)(b) of the Indo-USA DTAA by AO and DRP as the Data Centre and Infrastructure therein was used to provide services belonged to assessee and customer did not have physical control or possession over the servers and right to operate and manage this infrastructure/servers vested solely with assessee.
The issue under consideration is whether the late filing fees for TDS return u/s 234E is mandatory in nature or it can be condone if there is reasonable cause?
whether the AO is correct in chargeing capital gain in the hands of assessee irrespective of the fact that the full consideration not received by the assessee?
The issue under consideration is whether the addition made by AO under section 68 in respect of the deposit of business of wife in their joint bank account is justified in law?
The issue under consideration is that Whether the receipts of the assessees from transponder is royalty under the Income Tax Act, 1961, and if the answer is in the affirmative, whether it is taxable?
Since clause (i) section 92A was omitted with effect from 1st April, 2017 and the effect of such omission is that the said clause(i) was never existed in the statute. Hence, Ld. PCIT can not exercise the jurisdiction u/s 263 of the Act.
