ABB Global Industries and Services Pvt. Ltd. Vs DCIT (ITAT Bangalore) A perusal of the order of the AO shows that the AO called upon the assessee to justify the allowability of the losses on account of exchange loss on forward contracts. The assessee gave two submissions dated 8.1.2014 and 23.1.2014, copies of which are […]
Joseph K. Zachariah Vs ACIT (ITAT Bangalore) Section 54(2) of the Act has two conditions for availing deduction u/s 54(1) of the Act. Firstly, the assessee has to utilize the capital gain in purchase of new property before the due date of furnishing the return of income u/s 139 of the Act, which encompasses sub-section […]
Bangalore Turf Club Ltd. Vs ACIT (ITAT Banglore) Assessing Officer argued that the Finance Act, 2001 has inserted the words ‘card game or other game of any sort’ in Section 194B of the Act which will even cover the “stake money” which is otherwise not covered by Section 194BB of the Act. We find that […]
JCIT (LTU) Vs M/s. Texas Instruments (India) Pvt. Ltd. (ITAT Bangalore) As per the submissions made by Ld A.R, we notice that the disallowance of Rs.5.54 crores made by the AO forms part of Provision for expenses amount of Rs.9.71 crores created on 31.3.2006 relevant to AY 2006-07. It was submitted that the above said […]
M/s. Innaccel Technologies Private Ltd. Vs ACIT (ITAT Bangalore) The A.O. was of the view that the shares of the company have been over valued and accordingly asked the assessee to justify the valuation. After considering the explanations of the assessee, the A.O. took the view that the valuation report has been prepared on the […]
DCIT Vs Coffeeday Enterprises Ltd (ITAT Bangalore) In terms of section 195, the liability to withhold taxes arrears at the time of payment/credit of any interest (or any other sum) which is chargeable under the provisions of the Act. The payment/credit was not made till 31.03.2010 and also in terms of the Agreement, interest was […]
Indraprastha Shelters Pvt. Ltd. Vs DCIT (ITAT Bangalore) With regard to the other reason given by the revenue authorities for denying deduction of interest paid to Mrs.Kaveri bai is by applying the 3rd proviso to Sec.24(b) of the Act. On perusal of the provisions of section 24(b), it is clear that the deduction is allowed […]
SAP India Pvt. Limited Vs Commissioner of Central Excise (CESTAT Bangalore) By the impugned orders in the above appeals, the respondent has confirmed the demand of service tax on the licence fee paid to SAP AG, Germany, for grant of non-exclusive licence to use, market and sublicense the software, third party database and third-party software […]
Google India Private Limited Vs JCIT (ITAT Bangalore) By this Stay Petition, the assessee is seeking to stay the recovery of outstanding tax arrears of Rs.1260,56,49,209. 2. Originally the stay was granted vide the order dated 20.11.2019 of the Tribunal in SP No. 293/Bang/2019, for a period of six months. As per the original stay […]
Provision for software expenses could not be disallowed by considering it as contingent liability as assessee was required to make provision for all known liabilities and losses as per accounting standards prescribed by ICAI and also by the Central Government under the Income Tax Act even though the amount could not be determined with certainty.
