ITAT Delhi held that TDS under section 194C of the Income Tax Act is deductible on payments made towards bus hire charges and wharfage charges.
ITAT held that Interest under section 234B and 234C not chargeable, if entire income of the assessee was subjected to TDS.
ITAT Delhi held that TDS under section 194A of the Income Tax Act duly deductible on interest paid by subsidiary company to its holding company.
ITAT Delhi held that interest income on income tax refund is chargeable at the rate of 10% as per Article 11 of India – Japan tax treaty.
n this case addition was made u/s.14A r.w. Rule 8D by AO and confirmed by CIT (A) holding that Amendment in Finance Act, 2022 in relation to disallowance u/s.14A r.w. Rule 8D is applicable retrospectively even if no exempted income was earned by assessee.
ITAT Delhi held that investment done from the surplus funds in FDs has nothing to do with the business connection. Accordingly, interest received from the same is to be treated under separate head i.e. Income from other sources and not as business income.
Held that if such loan or advances given to such shareholder as a consequence of any further consideration, which is beneficial to the company received from such shareholder then in such advance or loan cannot be said to be deemed dividend within the ambit of section 2(22)(e) of the Act.
ITAT Delhi held that penalty under section 271(1)(c) of the Income Tax Act cannot be imposed on the basis of legal fiction of section 50C of the Income Tax Act.
ITAT Delhi held that expenditure of customer contracts and assembled workforce incurred which will give enduring benefits to the assessee is capital expenditure. Accordingly, depreciation is allowable on the same.
ITAT Delhi held that receipts from leasing- hiring of Rigs are taxable as business profit under section 44BB of the Income Tax Act. Such receipts are not in the nature of royalty and hence cannot be taxed under section 9(1)(vi) read with section 115A of the Income Tax Act.
