Muradul Haque Vs ITO (ITAT Delhi) Finance (No.2) Act has made amendment to section 40(a)(ia) of the Act w.e.f. 01.04.2015. Various benches of the Tribunals including the Delhi Benches of the Tribunal, have held the amendment made by Finance (No 2) Act to be curative in nature. We further finds the coordinate bench of the […]
Whether the disallowance of Interest u/s 36(1)(iii) is justified in law? If interest free funds available it presumed that Investments made from that available funds.
The issue under consideration whether conversion of the case from limited scrutiny to complete scrutiny is justified in law?
Deepak Bhardwaj Vs ITO (ITAT Delhi) Only question that arises for our consideration is whether the unutilised portion of capital gains is liable for tax either in the year in which such long term capital gains arose or in the year in which the period of 3 years for such utilisation expires. Under identical facts […]
SPX India Pvt. Ltd. Vs CIT (ITAT Delhi) Tax was required to be deducted at source on share of ISO audit expenses paid to foreign parent company, as element of income was embedded in receipt of auditor. FULL TEXT OF THE ITAT JUDGEMENT Assessee is in appeal before us against the order of ld. CIT […]
Convergys Customer Management Group Inc. Vs ADIT (ITAT Delhi) The assessee made payment for link charges to telecom service providers in the USA and cross-charged the portion of the cost incurred by it in connection with the India half link to CIS, which was accordingly reimbursed by CIS to assessee. The assessee has merely procured […]
AMP expenditure of assessee did not have a direct bearing on the promotion of brands of its AEs as the issue stood decided in favour of assessee by the decision of the Tribunal in assessee’s own case for the preceding assessment years i.e., A.Y. 2007-08 and 2008-09.
The issue under consideration is that Whether the receipts of the assessees from transponder is royalty under the Income Tax Act, 1961, and if the answer is in the affirmative, whether it is taxable?
Air France Vs Addl. CIT International Taxation (ITAT Delhi) The issue under consideration is whether Indian branch is deriving income from technical handling to IATP Pool Members and non IATP Members is taxable in India? ITAT states that, in the present case, it can be seen that the Indian Branch office is merely a branch […]
Lease Plan India Pvt. Ltd Vs DCIT (ITAT Delhi) These appeals are against disallowance made by the learned assessing officer under section 40 (a)(i) on account of non-deduction of tax at source on guarantee commission paid to lease plan Corporation NV Netherland is confirmed holding it to be payment in nature of Fees For Technical […]
