The issue under consideration is whether the provisions of deduction of tax at source (TDS) would be applicable in case of payments made to non-resident Indian for the purchase of raw materials?
The issue under consideration is Unlisted shares sold after holding for 23 months considered as Long Term Capital Gains or Short Term Capital Gains?
In the present case, the A.O, came to the conclusion that since assessee company purchased the same shares just after 05 days from TIDCL at a much lower price, therefore, assessee must have paid the sale consideration outside the books of account. Accordingly, A.O. in the assessment order held that assessee has paid to TIDCL outside books of account and made addition accordingly.
The issue under consideration is whether short of the jewellery found during search be treated as sold and capital gain attracted?
The issue under consideration is whether depreciation will be levied on the intangible being CMS software? CMS, which has been developed by the assessee is computer application which supports the creation and modification of content and is often used to support multiple users working in a collaborative environment.
AO recording reasons on same returned income considering escaped assessment but making various other additions of other than accepted returned income declared invalid and deleted in light of Explanation 3 and held issuance of fresh notice u/s 148 on other issues is mandatory.
DE Diamond Electric India Pvt Limited Vs ACIT (ITAT Delhi) One of the ground taken by the AO for invoking section 40A(2)(b) is the agreement between the parties has not been registered. In our opinion, an unregistered agreement cannot be a ground for invoking provisions of section 40A(2)(b) of the Act in absence of requirement […]
Aspect Software Inc Vs DCIT (ITAT Delhi) Consideration received by the Assessee for supply of product along with license of software to End user is not royalty under Article 12 of the Tax Treaty. Even where the software is separately licensed without supply of hardware to the end users (i.e. eight out of 63 customers), […]
The issue under consideration is whether the Ao is correct in levying penalty u/s 271C for failure to deduct tax at source u/s 194C on payment of external development work charges (EDC)?
the assessee requested an opportunity to explain the case and to submit all the necessary information & documents to the Assessing Officer since his counsel did not attended the decided hearings to solve the case.
