Reopening of assessment to assess the remuneration under the head ‘income from salary’ instead of ‘income from other sources’ constitutes difference of opinion and the AO is not permitted to reopen the assessment on difference of opinion
The issue under consideration is whether the submission of Form 35 alongwith scanned copy of signature at the time of filing CIT appeal is sustainable in law?
Procter & Gamble Home Products Private Limited Vs DCIT (ITAT Mumbai) Main allegation of the revenue is that of non-furnishing of audited AE and non AE segmental as well as documents regarding choice of foreign entity as tested party. We also noted that any other reason for levy of penalty is for non-furnishing of audited […]
ITO Vs M/s Heckyl Technologies Pvt.Ltd. (ITAT Mumbai) Firstly, the AO has clearly mentioned at paragraph no. 5 on page no’s, 6 and 7 of his order that he had made two references to the tax authorities in Mauritius and the UK. These references had been made under section 90 of the Act and had […]
DCIT Vs Vodafone India Ltd. (ITAT Mumbai) We find that for installation / setting up / repairing / servicing / maintenance capacity augmentation are require human intervention but after completing this process mere interconnection between the operators is automatic and does not require any human intervention. The term Inter Connecting User Charges (IUC) also signifies […]
Atos India Pvt. Ltd. Vs DCIT (ITAT Mumbai) The issue under consideration is whether the assessment initiated in the name of a non-existing entity is justified in law? ITAT states that, even after the learned DRP taking into account the fact of merger and passing order by giving directions to the learned AO in the […]
The issue under consideration is whether the re-opening of assessment u/s 147 of the Act is justified in law?
whether addition made by AO u/s 68 as Unaccounted/Unexplained Income by treating the Long Term Capital Gain as Manipulated Transaction is justified in Law?
The issue under consideration is whether transfer pricing adjustment as notional interest and charging it to tax, disregarding the provisions of Article 11 of India Cyprus DTAA is justified in law?
The issue under consideration is whether the penalty notice u/s 271(1)(c) issued to the assessee who has taxed his income as per provision of section 115JB pr 115JC is justified in law?
