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.
Delve into the case of Paramjit Singh Vs PCIT (ITAT Delhi) regarding jurisdiction under section 263 of the Income-tax Act, 1961, and its impact on reassessment orders.
Delhi ITAT remits matter in ACIT vs Grass Valley India Pvt Ltd case, criticizing CIT(A) for perfunctory defense, lack of inquiry on expenses, and orders fresh determination.
Delve into the case of Asha Modern Educational Society challenging the denial of income application for charitable purpose under Sections 11 & 12 of the IT Act. Detailed analysis and conclusions provided.
Detailed analysis of the Delhi ITAT’s ruling in ACIT Vs Dhruv Milkose Pvt. Ltd., regarding the taxation of premium charged on the issue of shares to existing shareholders under Section 56(2)(viib) of the Income Tax Act.
DCIT vs Continental Corrugators Pvt. Ltd. – Delhi ITAT rules Rule 11UA(2)(A) doesn’t require a valuation report for substantiation under NAV method for determining FMV. Full analysis here.
ITAT Delhi held that PCIT cannot assume revisional jurisdiction under section 263 of the Income Tax Act when in case of debatable issue, out of the two possible views, AO accepts one of the views.
