ITAT held that the amount received by the assessee from sale of software and provision of software related services cannot be treated as royalty under Article 12(3) of the India – Singapore DTAA.
Malook Nagar Vs ACIT (ITAT Delhi) Since the AO has not been specified u/s 274 as to whether penalty is proposed for alleged ‘concealment of income’ OR ‘furnishing of inaccurate particulars of such income’, the penalty levied is hereby obliterated. FULL TEXT OF THE ORDER OF ITAT DELHI The present appeals have been filed by […]
GSA Gestions Sportives Automobiles SA Vs DCIT (ITAT Delhi) The Income Tax Appellate Tribunal (ITAT), Delhi bench has held that penalty can’t be invoked under Income Tax Act without relevant documents which substantiate business activities. The appellant GSA (Gestions Sportives Automobiles) is a company engaged in providing services of qualified motor racing drivers to teams […]
Asha Saini Vs ITO (ITAT Delhi) It is not a case of the Assessing Officer that the assessee was the ultimate beneficiary of the amounts deposited in the bank account. Hand-writing expert report dated 2.12.2017 and copy of FIR available at assessee’s paper book clearly reveals that the hand-writing expert clearly opined that the disputed and […]
Vikram Kalra Vs ACIT (ITAT Delhi) It is the case of the assessee that the provisions of Section 54F are beneficial in nature and the Courts have always accorded liberal interpretation and a small delay of few days have been condoned for the eligibility purposes. Even otherwise, in these circumstances, the imposition of penalty on […]
Delhi ITAT allows deductions for delayed but pre-return-filing PF/ESI contributions, citing High Court rulings and Finance Act 2021’s prospective effect.
Whether any addition can be made and confirmed in the hands of assessee on account of cash deposit of Rs.2,30,000- during demonetization
ITAT held that passing the assessment order against non existing entity is not sustainable in the eyes of law and the same is void ab initio.
After considering detailed reasoning by AO as to how assessee has introduced unaccounted money in the garb of LTCG, ITAT upheld addition.
DCIT Vs Flt Lt. Rajan Dhall Charitable Trust (ITAT Delhi) he issue in the present ground is with respect to the denial of claim of Rs.3.32 crores (rounded off) as application of income on account of provisions for doubtful debts. We find that CIT(A) after considering the submissions of the assessee has given a finding […]
