Analysis of ITAT Delhi’s ruling: Sale of software products not taxable as royalty under India-Japan DTAA, citing Engineering Analysis case. Details of DCIT Vs Dassault Systems Biovia K.K.
ITAT Delhi held that expense towards management and marketing support service paid to foreign company is not taxable under Fee for Technical Service (FTS) under India-Netherlands Double Taxation Avoidance Agreement (DTAA) and hence TDS not deductible u/s. 195 of the Income Tax Act.
ITAT Delhi held that the reopening of assessment had been initiated by mere surmise and conjecture without having any cogent material to form a reasonable belief that income of the assessee had escaped assessment within the meaning of section 147 of the Income Tax Act.
Discover the ITAT Delhi ruling on taxing income from providing business support services to Indian group entities. Analysis of Solvay Asia vs. DCIT case under India-Thailand DTAA.
ITAT Delhi ruling: Loan advanced for repayment of business operation liabilities considered allowable as business expenditure under section 37(1) of the Income Tax Act.
Assessing Officer computed a disallowance under section 14A concerning non-current investments. However, the assessee had not claimed any exempt income. Citing relevant legal precedents, the Tribunal dismissed the disallowance, affirming that section 14A was inapplicable in the absence of exempt income.
ITAT Delhi held that revenue received from various hotel owners for providing various centralized services cannot be treated as fees for included services (FIS) either under Article 12(4)(a) or 12(4)(b) of the India-US tax treaty. Thus, in absence of PE in India, the same is not taxable.
Explore the ITAT Delhi ruling on the eligibility of management service fees paid to non-resident AEs under section 37(1) of the Income Tax Act in the case of Iris Worldwide Integrated Marketing Pvt. Ltd vs. DCIT.
Delhi ITAT ruling on Manish Kumar Mittal Vs ITO case clarifies treatment of cash-in-hand from business profits declared under Sec 44AD, preventing it from being added as unexplained money.
In the case of Mandeep Singh Anand Vs ACIT, the Income Tax Appellate Tribunal (ITAT) Delhi ruled that the Commissioner of Income Tax (Appeals) cannot add a new source of income without issuing an enhancement notice. Get insights into the case and the tribunal’s decision.
