The issue under consideration is whether the assessment u/s 153A can be considered as valid even if no incriminating material found during the course of search?
Ld. AO/ Ld. TPO/ Ld. DRP erred in using a LIBOR based interest rate to benchmark the international transaction of payment of interest on FCCDs denominated in Indian Rupees
Merely earning surplus by assessee did not result into the conclusion, that assessee was carrying on its activities, which could be termed as business, trade, or commerce, charging a nominal fee to use coding system and to avail of advantages and benefits therein was neither reflective of business aptitude nor indicative of profit-oriented intent. Accordingly, proviso to section 2(15) did not get attracted, and hence, there was no justification for denying exemption under section 11.
The issue under consideration is whether the marketing expenditure incurred on account of issuance of handsets on free of cost basis is allowed as business expense or not?
Motherson Sumi Infotech & Designs Ltd. Vs DCIT (ITAT Delhi) We find that the next issue raised is against the transfer pricing adjustment made on account of interest due on receivables outstanding. The said issue stands covered in favour of the assessee by the decision of the Tribunal in M/s. Global Logic India Ltd. for […]
DCIT Vs Venus Overseas Pvt. Ltd. (ITAT Delhi) The common grievance in all these appeals relates to the deletion of the addition made u/s 68 of the Act on account of unexplained share capital and premium though quantum may defer in each year. Vide application dated 30.01.2020, the assessee has invoked Rule 27 of the […]
The issue under consideration is whether order passed by the AO held that the draft order framed under Section 144C(1) of the Income Tax Act is in the name of a non-existent company is sustainable in law?
The issue under consideration is whether the issue of notice u/s 153C instead of section 153A is considered as valid assessment or not?
ACIT Vs Volvo Auto (India) Private Limited (ITAT Delhi) The issue under consideration is whether CIT(A)is correct in deleting the addition made on application of CUP method for determination of ALP of international transactions by the A.O.? ITAT states that, the AO’s observation that this expenditure has been debited to the profit and loss account […]
The issue under consideration is whether disallowance of relocation expenses u/s 40(a)(i) of the Act and non granting of tax deducted at source with respect to that expense is justified in law?
