ITAT Bangalore held that interest under section 234A cannot be levied when the return of income is filed within the time stipulated in section 139(1) of the Income Tax Act.
ITAT Bangalore held that deduction under section 10A/ 10B of the Income Tax Act allowable as the assessee has obtained post facto approval from RBI coupled with the fact that it has also realized the said amounts.
ITAT Bangalore held that addition under section 69B of the Income Tax Act for unexplained investment solely on the basis of the document that didn’t contained name of the assessee is unsustainable as the same is outside the purview of definition of section 153C(1)(a) & (b).
LLP is to be treated as a firm under Income Tax Act, 1961 and a firm can be a partner in other partnership firms therefore, LLP is eligible to exemption under Section 10(2A) on share of profit received from other partnership firms.
Purchase of online advertisement space for onward resale to Indian advertisers did not amount to Royalty as unless the non-resident, who was engaged in sale of online advertisement space, had a PE in India, no portion of receipts earned by it from sale of online advertisement space in India could be brought to tax in India as Act read with the relevant DTAA. Thus, assessee was not in default u/s 201, for not deducting the tax at source, on the payment in question, under the section 195.
ITAT held that high turnover is a ground to exclude a company from the list of comparable companies in determining ALP, held that there were contrary views on the issue and hence the view favourable to the Assessee laid down in the case of Pentair Water (supra) should be adopted.
Subramanya Karthik Vs ITO (ITAT Bangalore) ITAT held that decisions cited by the learned Counsel for the assessee proceed on the assumption that the disallowance of employees’ share of PF and ESI paid beyond the due dates under relevant law has been made only under section 143(1)(a)(iv) of the Act, while in the intimation under […]
ITAT Bangalore held that disallowance merely considering the provisions of section 144C(8) of the Income Tax Act without verification of details furnished by the assessee is unsustainable in law.
Order passed u/s.263 is invalid and shall be deemed to have never been issued if it does not contain the DIN
Toyota Kirloskar Motor (P) Ltd Vs ACIT (ITAT Bangalore) The Appellant submits the in its own case for AY 2003-04, the Honourable Bangalore Tribunal has accepted that TP adjustment has to restricted to AE transactions. Further, in Appellants own case for AY 2013-14 [ITA No.2016/Bang/2018, dated 18.08.2021], the Honourable Bangalore Tribunal has upheld the action […]
