Read the detailed analysis of Sarva Capital LLC Vs ACIT (ITAT Delhi) regarding the validity of Tax Residency Certificate (TRC) for determining treaty benefits under the India-Mauritius Double Taxation Avoidance Agreement (DTAA).
Delhi ITAT rules in favor of Volvo Information Technology AB, declaring receipts from Indian entities not taxable as royalty, aligning with SC precedents.
ITAT held that taxation should be based on real income. It found that the AO’s attempt to tax hypothetical income was unjustified. Furthermore, it was established that the credit note adjustments made for benchmarking purposes were legitimate and in accordance with the tax provisions.
ITAT Delhi held that as conditions prescribed in exception to section 9(1)(vii)(b) stand fulfilled, it cannot be taxed as FTS. Further, the source for making or earning any income of the payer of fee for technical services, in the present case, is outside India, and therefore not taxable in India.
Explore the ITAT Delhis decision on the disallowance of service tax by ACIT in the case of S & A Finman Ltd. for the assessment year 2012-13. The article provides insights into the legal arguments and precedents.
Explore the details of Shyamkumar Madhavdas Chugh Vs ACIT case at ITAT Delhi. Analysis of additions, considerations, and legal perspectives leading to the verdict.
Read the full text of ITAT Delhi’s order in Sunil Ghorawat vs ACIT case. Analysis of no TDS on consultancy charges under Sec 194J and short term capital loss disallowance.
Delhi ITAT addresses Pr.CIT’s revisional order on Section 54F deduction misuse for AY 2017-18 in Anju Ahuja vs PCIT, clarifying legal interpretations.
Read the detailed analysis of the ITAT Delhi order regarding the taxability of income from offshore supplies of plants and equipments in the case of Air Liquide Global EC Germany GMBH Vs ACIT.
ITAT Delhi allows Oravel Stays’ appeal against CIT(A)’s order, removing disallowance under section 40(a)(ia) for not deducting TDS on minimum guarantee expense.
