ITAT Delhi held that amount received from its Indian subsidiary towards IT and SAP charges cannot be treated as Fees for Technical Services (FTS) under Article 12(4)(a) of India – Portugal DTAA. Accordingly, additions unsustainable.
ITAT Delhi held that statue doesn’t empower the Assessing Officer to withdraw or modify or substitute the assessment order passed under Section 143(3) of the Income Tax Act with another assessment order.
ITAT Delhi holds in the Sabharwal Food Industries Vs DCIT case that penalty under section 271(1)(c) cannot be levied simply because a claim was not accepted. Discover more about this landmark ruling.
Analyze the case of DCIT vs. Software One Pte Ltd. (ITAT Delhi) regarding the taxation of software sales and royalty. Understand the distinction between copyright ownership and distribution rights, as well as the impact of the Supreme Court’s decision in the Engineering Analysis case.
Explore the case of Western Geco International Ltd vs. DDIT (ITAT Delhi) and decision regarding exclusion of reimbursement of service tax from gross turnover for computation of taxable income under Section 44BB of Income Tax Act.
ITAT Delhi held that Common Area Maintenance charges (CAM Charges) paid by the assessee are liable for 2% TDS u/s 194C of the Income Tax Act and not at 10% u/s 194I of the Income Tax Act.
ITAT Delhi held that the receipts from centralised service income are not taxable as Fees for Technical Services (FTS)/ Fees for included Services (FIS) under Article 12(4)(a) of India-USA DTAA.
ITAT Delhi held that issuance of notice by AO in the status of ‘Local Authority’ and assessment framed in different status i.e. in the name of ‘Artificial Juridical Person’ is bad in law and hence liable to be cancelled.
A comprehensive review of the landmark decision by ITAT Delhi in the SFS Infinite Ltd Vs DCIT case, examining the quashing of reassessment based on insufficient and obscure information.
ITAT Delhi held that difference between service tax return and the revenue was occurred due to the wrong exchange rate applied to export income transaction while filing the service tax return. Hence, mere mistake in the service tax return does not mean that the income of the assessee has been suppressed.
