Bombardier Transportation Sweden AB Vs DCIT (ITAT Delhi) Conclusion: Payment of consideration would be regarded as ‘fee for technical/included services’ only if the twin test of rendering services and making technical knowledge available at the same time was satisfied. Intermediary services rendered by assessee did not make available any technical knowledge, skill etc to BTIN […]
The issue under consideration is whether the re-opening of assessment is valid even if there is no addition on subject-matter being basis for issuing notice under section 148, rather AO made addition on other counts?
Commission paid to Director in terms of Employment is Considered as Part of Salary. It is also not disputed that TDS has been deducted on such commission as salary. Accordingly, the Revenue’s appeal is dismissed.
The issue under consideration is whether addition made by AO by application of N.P. rate of 8% is justified in law? Profit Margin Cannot be Rejected Arbitrarily due to Rejection of Books of Account
The issue under consideration is whether the addition made u/s 68 for assessee helped various beneficiaries in providing accommodation entries in relation to capital and expenses is justified in law?
The issue under consideration is whether CIT(A) is correct in disallowing managerial and administrative expenses for earning dividend income by treating this as tax free income?
ACIT Vs Him Urja Pvt. Ltd. (ITAT Delhi) The assessee has also submitted before the Ld. CIT(A) that as there was no exempt income earned by assessee during the relevant previous year, no disallowance under section 14A could be made. The assessee relied upon Judgment of the Hon’ble Delhi High Court in the case of […]
Paschimanchal Vidhyut Vitran Nigam Ltd. Vs DCIT (ITAT Delhi) AO noticed that assessee had made assessment of electricity duty of Rs. 5,52,98,00,000/- of which Rs. 3,44,22,00,000/- was adjusted from the subsidy and the balance amount of Rs.2,08,76,00,000/-was not paid by the assessee before filing the return of income. Assessee was asked to justify as to […]
The issue under consideration is whether the disallowance made by AO u/s 14A is justified in law? In view of the fact that no proper satisfaction was recorded, in our considered opinion, the Assessing Officer did not acquire any valid jurisdiction for computing disallowance u/s 14A.
Standard Chartered Grindlays Bank Vs ACIT (ITAT Delhi) The assessee is a non-resident banking company which carries on the business of banking and other related activities through its branches in India in accordance with the provisions of Banking Regulation Act, 1949. During the year, Indian Permanent Establishment (in short PE) of the assessee bank in […]
