ITAT Delhi held that that the departmental authorities cannot question the validity of Tax Residency Certificate. Once the assessee holds a valid TRC, it proves the residential status of the assessee as resident of Mauritius, hence, it will be eligible to treaty benefits.
ITAT Delhi held that addition on account of attributing income from offshore supplies to permanent establishment in India unjustified in case of loss.
An analysis of ITAT Delhi’s order in ITO Vs Santur Builders Pvt Ltd, stating that TDS is not applicable on EDC payments to HUDA on behalf of State Government.
ITAT Delhi held that cost to cost reimbursement on account of secondment of employees cannot be treated as Fees for Technical Services (FTS) as defined under Article 12 of India USA-Double Tax Avoidance Agreement (DTAA).
Insights into ITAT Delhi’s verdict on the denial of income tax deduction due to belated returns under Section 139(4) of the Income Tax Act for AY 2019-20.
Analysis of ITAT Delhi’s ruling in DCIT vs Centum Learning Ltd on debts claim, business nexus & re-adjudication. A critical look at the order dated 12.04.2019.
ITAT Delhi deletes section 68 addition in B N Public School vs ACIT, confirming no separate PAN or return needed for institution owned by trust/society.
Analysis of ITAT Delhi’s ruling in Bushra Javed Vs ACIT: Indexation benefits for acquisition costs based on payment year. Read the full legal insight here.
ITAT Delhi held that amount which was mistakenly received and returned with interest by virtue of order of the Court is allowable as deduction under section 37 of the Income Tax Act.
ITAT Delhi held that penalty notice under section 271(1)(c) without specifying the limb is vague and ambiguous, accordingly, penalty proceedings not sustainable.