ITAT Delhi held that passing of project-specific architectural drawings and designs with measurements did not amount to making available technical knowledge, know-how, or processes. Since ‘make available’ clause is not satisfied, services rendered to the AOP does not fall within the purview of FIS under Article 12(4)(b) of the India-USA DTAA.
ITAT Delhi held that supplemental rent/maintenance reserve would be exempt from tax in the hands of lesser in India as per Section 10(15A) of the Act and hence, no disallowance u/s 40(a)(ia) for non-deduction of TDS. Hence, TDS not deductible on such amount paid to foreign company for acquiring aircraft on lease.
Read the full text of ITAT Delhi’s order in the case of Sadhna Goyal vs DCIT, where the appeal was allowed due to a violation of the principle of natural justice.
ITAT Delhi held that issuance of notice u/s. 148 of the Act by the Income Tax Officer having no jurisdiction over the assessee and consequent assessment made u/s. 143(3) read with section 147 of the Act is void and bad in law.
ITAT Delhi held that rejection of Discounted Cash Flow (DCF) Method for valuation of share price unjustified as that the methodology adopted was a recognized method of valuation and the Revenue was unable to show that the assessee adopted a demonstrably wrong approach.
ITAT Delhi held that addition of interest free security deposit sustained as the same is not refunded to the Developer even after lapse of more than seven years by merely stating that the Developer had not provided completion certificate.
The appeal in the case of Simple Singh vs. ITO was directed against the order of the Commissioner of Income-tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi, for the assessment year 2011-12
Agasthya Auto Products LLP filed an appeal against the order of the Commissioner of Income Tax (Appeals) for the assessment year 2011-12. The appeal raised multiple grounds, challenging the validity of the reassessment proceedings initiated by the Assessing Officer (AO) under Section 147 of the Income Tax Act, 1961.
The ITAT Delhi dismissed an appeal by Yogender Kumar and confirmed the levied late filing fee for a delay in filing a TDS statement, reinforcing the importance of timely compliance with TDS provisions.
Explore the critical decision in Souvik Mukherjee Vs ITO (ITAT Delhi) regarding taxation of a bonus received abroad, and how it impacts Foreign Tax Credit regulations.
