The assessee company provides back office support services to AEs with the help of tools, infrastructure and training provided by the AEs which is different than the functions of the KPO.
Dabur India Ltd. Vs ACIT (ITAT Delhi) We have heard both the parties and perused the relevant material available on record. As regards to agreement with Dabur Nepal Pvt. Ltd. Nepal, it is pertinent to note that the issue stands covered in favour of the assessee by the order of the Tribunal in the asssessee’s […]
Star Facilities Management Limited VS ITO (ITAT Delhi) he only question to be decided in the grounds raised by the assessee is regarding the allowability of employees’ contribution to PF and ESI if deposited after the due date prescribed under the relevant Act, but, before the due date of filing of return of income u/s […]
Pachouli Wellness Clinic LLP Vs ITO (ITAT Delhi) It is not in dispute that the payments on account of PF/ ESI were made by the assessees after due date prescribed under the respective acts, but before due date of filing of return under the I.T. Act. The Ld. Sr. DR has also not contradicted the […]
Since the issue of benchmarking the international transaction is required to be examined qua both the segments i.e. CSDS and ITES separately and independently for factual analysis of taxpayer’s TP study, the case is remanded back to ld. TPO who shall determine the ALP of international transactions of both the segments independently afresh after providing an opportunity of being heard to the parties.
ITO Vs Indian Youth Centre Trust (ITAT Delhi) The assessee company is a trust registered u/s 12A of the Act and is also registered u/s 80G(5)(vi). The return filed by the assessee trust was subjected to the scrutiny assessment. In the course of the scrutiny assessment the Assessing Officer took a view that the receipts […]
Sh. Chander Mohan Lall Vs ACIT (ITAT Delhi) A plain reading of section 40A(2) of the Act would make it clear that where the payment made to a related party, in the opinion of the Assessing Officer, is excessive or unreasonable having regard to the fair market value of the goods, services or facilities for […]
Vijayshree Food Products P. Ltd. Vs ACIT (ITAT Delhi) The reopening has been challenged by the assessee stating that initiation of proceedings u/s 147 of the income tax act is solely on the basis of the unverified, on rectified, unsubstantiated and unconfirmed statement of Mr Malu. It is further the claim of the assessee that […]
ACIT Vs PC Jewellers Ltd. (ITAT Delhi) Facts- AO disallowed the bank guarantee commission and credit card commission u/s 40(a)(ia) on the grounds that TDS is not deducted. AO rejected the diamond purchase from commission agent and added income @12.5% on the purchase alleging purchase as inflation of purchase price on purchases from accommodation entry […]
Statement under section 132(4) alone cannot be considered as incriminating material unless any corroborating incriminating material is found during the course of search from the premises of the assessee.
