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Rule 128(9) not provide for disallowance of FTC in case of delay in form 67 filing

June 25, 2024 240 Views 0 comment Print

Explore the ITAT Delhi’s ruling in Rameshwar Prasad Shrivastava vs ITO, detailing the disallowance of foreign tax credit due to procedural lapses, implications under DTAA, and judicial precedents.

Income Tax Addition cannot Be based Solely on unsubstantiated Loose Slips

June 25, 2024 603 Views 0 comment Print

The ITAT Bangalore ruled that income tax additions can’t be based solely on unsubstantiated loose slips, emphasizing the need for corroborative material evidence.

Alleged Bogus LTCG: AO’s Non-Addition Not Automatically makes order Erroneous

June 25, 2024 354 Views 0 comment Print

ITAT Jaipur rules that AO’s non-addition of bogus LTCG does not make the order automatically erroneous. Detailed analysis of Vipul Kumar Modi vs PCIT case.

Section 14A disallowance based on presumptions of earning dividend income in future is unsustainable 

June 25, 2024 261 Views 0 comment Print

Read the detailed analysis of Zodiac Ventures Ltd. vs. ITO case by Mumbai ITAT regarding income tax disallowance based on presumptions of future dividend earnings. Full text of the ITAT order included.

ITAT Deletes On Money Addition as document falls short of material facts

June 25, 2024 324 Views 0 comment Print

ITAT deletes On Money addition due to incomplete documentation lacking key details: payment dates, parties involved, and agreement specifics.

Foreign Tax Credit cannot be denied for delay in filing Form 67: ITAT Delhi

June 25, 2024 183 Views 0 comment Print

Read a comprehensive analysis of Ajay Kumar Mishra Vs DCIT case at ITAT Delhi regarding disallowance of foreign tax credit under Indian tax law. Understand the implications and legal arguments presented.

Creditworthiness of Share Subscribers Proven: ITAT Deletes Addition

June 25, 2024 183 Views 0 comment Print

Read about Wisley Real Estate Pvt. Ltd Vs ITAT Kolkata. Detailed analysis of the case where creditworthiness of share subscribers was proven, resulting in deletion of Rs. 1,76,87,500/- addition under section 68 of IT Act.

Form 67 submission Not Mandatory for Availing  Foreign Tax Credit: ITAT Delhi

June 24, 2024 483 Views 0 comment Print

Read the full text of the ITAT Delhi order in Suchi Agrawal vs. ITO, where the requirement of Form-67 for foreign tax credit was debated and its procedural nature clarified.

Deeming provision of 56(2)(x) cannot be invoked in case of Purchase of agricultural land

June 24, 2024 744 Views 0 comment Print

ITAT Delhi rules Section 56(2)(x) can’t be invoked for agricultural land purchases, providing relief to taxpayers in similar situations.

CSR Expenses Eligibility for Section 80G Deduction: ITAT restores Matter to CIT(A)

June 24, 2024 348 Views 0 comment Print

Detailed analysis of ABIS Export India Pvt Ltd Vs DCIT (ITAT Raipur) case regarding CSR expenses deduction under Sec. 80G. Explore the ITAT’s decision, implications, and legal insights.

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