ITAT Mumbai allows Transfer Pricing determination for Rallis India Ltd. using the ‘Other Method’ instead of CUP. Key points on ALP adjustments and deductions.
As noticed earlier, the provisions of sec. 147 of the Act makes it mandatory that the AO should be clear about the alleged escapement of income while recording reasons for reopening of assessment.
ITAT Mumbai held that benefit of cost inflation index admissible as per second proviso to section 48 of the Income Tax Act. Accordingly, indexation benefit admissible even in respect of assets held in foreign countries.
ITAT Mumbai held that validity of notice issued under section 148 of the Income Tax Act for AY 2015-16 is six year which expires on 31.03.2022. Accordingly, notice issued on 29.07.2022 u/s. 148 is barred by limitation.
The stand of the assessee was that it was not necessary that loss of one industrial undertaking should necessarily be adjusted against the profit of another eligible industrial undertaking.
ITAT Mumbai dismisses the appeal of Veermata Jijabai Technological Institute under Direct Tax Vivad Se Vishwas Scheme for AY 2017-18.
ITAT Mumbai rules on ACIT vs Rohit Krishna, dismissing penalties under Section 43 of the Black Money Act for non-reporting of foreign assets in tax returns.
ITAT Mumbai held that addition u/s. 68 towards amount received as gift from son not justified since addition is made in a baseless manner, solely relying on unverified newspaper reports. Accordingly, appeal of revenue dismissed.
ITAT Mumbai held that the internal audit memo is outside the scope and ambit of the term “information” as provided in Explanation 1 to section 148 of the Act, prior to its amendment by the Finance Act, 2022. Accordingly, reopening of proceedings liable to be quashed.
ITAT Mumbai held that interest paid on loan from group entities are in the nature of reimbursement and therefore not liable for deduction of TDS. Therefore, addition made by AO is directed to be deleted.
