Courts: ITAT Bangalore
2,100 articlesIncome Tax
Income Tax
No restriction in considering companies with either abnormal profits / losses as comparable to tested party, as long as they are functionally comparable
Income Tax
Income Tax
TPO can’t include functionally different Companies in comparables for transfer pricing adjustment
Income Tax
Income Tax
ITAT asked AO to determine if payment for software service is FTS or Royalty
Income Tax
Income Tax
Even if a claim is not made before AO, it can be made before appellate authorities
Income Tax
Income Tax
Disallowance U/s. 40A(2) is not required to be made for TP adjustments
Income Tax
Income Tax
Dutch Company not eligible for benefits under India-Netherlands treaty, if it charters a ship from a company domiciled in Iran
Income Tax
Income Tax
S. 10B Set-off of eligible unit’s loss against income of non-eligible unit during tax holiday period cannot be allowed
Income Tax
Income Tax
S. 147 Supply of recorded reasons after passing reassessment order renders the reopening void
Income Tax
Income Tax
TPO cannot be asked to establish motive behind transfer of profit before ALP determination
Income Tax
Income Tax
Addition U/s. 41(1) not justified on failure of revenue to prove adjustment of liability
Income Tax
Income Tax
54EC limit of Rs. 50L applies to financial year not to transaction
Income Tax
Income Tax
‘Grossing up’ in absence of PAN should be at rates in force and not at 20%
Income Tax
Income Tax
Whether software expenditure is capital or revenue in nature is to be seen independently in respect of each software
Income Tax
Income Tax
