ITAT Delhi held that income of non-resident is not liable for deduction of tax at source u/s. 195 as amount paid is covered in exception provided in section 9(1)(vii)(b) of the Income Tax Act since project has been carried outside India and services are utilised outside India.
Read the full text of the ITAT Delhi order on Sec 56(2)(viib) and its implications for premium amounts on shares issued to holding companies.
Once an assessment has been finalized for a particular year, reassessment cannot be justified merely due to subsequent procedural events like re-registration of property deeds.
Read the detailed analysis of ITAT Delhi’s decision in Rhine Energy LLP vs Assessment Unit, allowing expenses on Buffet Dinner, Liquor, and Govt Taxes as business promotion under section 37(1) of IT Act.
ITAT noted that CIT(A)’s decision was reasoned, considering discrepancies in repayment timelines and absence of proper documentation or corroborative evidence. It concluded that CIT(A)’s findings were based on facts and did not merely rely on suspicion.
Merely because certain cash was deposited in the specified bank notes by the assessee during the demonetization period will not make the assessee tainted party when the very same transaction are being made by the assessee in the part as well as in the future.
Detailed analysis of Dhoom Singh Sharma Vs ITO case where ITAT Delhi accepts agricultural income proof, overturning Rs.16.4 Lakhs addition. Read the full order.
ITAT Delhi rules Section 56(2)(vii) inapplicable to non-residents, deleting Rs. 9.31 Cr addition for APL Logistics Vascor Automotive Pvt. Ltd. Read full order and analysis.
Read the full text of the ITAT Delhi order in Durga Fire Work Vs ITO case for AY 2017-18. Learn why Delhi ITAT ruled cash deposits during demonetization as non-taxable.
Explore the ITAT Delhi’s ruling on Raghunandan Mishra Charitable Trust’s 12A and 80G registration applications. Analysis of CIT(Exemption)’s ex-parte order and IT portal notice issue.
