ITAT Delhi held that assessment order passed in violation of the directions of Dispute Resolution Penal (DRP) is against the provisions of sub-section (10) and (13) of section 144C of the Act and hence liable to be quashed
ITAT Delhi held that property sold is to be taxed under Capital gain as the property was held for considerable longer period of time and assessee is not engaged into systemic real estate business activity.
Distribution revenue earned by assessee had already offered income as business income in terms of the Mutual Agreement Procedure (MAP) holding that 10% of the advertising and subscription revenue received from India should be deemed to be the net profit chargeable to tax in India, therefore, the additions made by AO were deleted.
ITAT Delhi held that disallow of any interest expenditure u/s 14A r.w. Rule 8D of the Act unsustainable as the interest bearing funds borrowed by the assessee have not been utilized for making the investments.
ITAT Delhi held that social security contribution doesnt constitute income from salary in the hands of expatriate employees. Hence disallowance u/s 40(ia) for non-deduction of TDS on the same is unsustainable in law.
Assessee was unable to furnish any cogent explanation supported by evidence to establish that the consultancy charges paid are not in the nature of FTS.
Arya Samaj Vs ITO (ITAT Delhi) Before ITAT, it was pleaded that the assessee has wrongly filled the column A(i) pertaining to “Other details” the ITR7 and since CPC is a automated process, the adjustment has also been wrongly made. It was argued that had there been a notice issued before making an adjustment, the […]
ITAT held that no tax would be levied on issue of shares to venture capital fund and further upheld observation of CIT(A) that, payment for valuation certification and retainership fees to a CA firm is a revenue expenditure.
Vipin Kumar Vs ITO (ITAT Delhi) ITAT Delhi held that benefit under section 54B of the Income Tax Act cannot be denied on mere fact that property was valued by the registered authority as a non-agricultural land for the purpose of stamp paper. Facts- The AIR information from sub registrar, Hapur Second in the case […]
ITAT Delhi held that provisions of section 292C of the Income Tax Act is only a deeming provision and the deeming provision cannot be applied mechanically, ignoring the facts of the case and surrounding circumstances.
