For arriving at the above conclusion, strength is drawn from the decision of Mumbai `L’ Bench of the Tribunal in the case of UCB India P. Ltd. v. ACIT [121 ITD 131 (Mum.)] where it was held that section 92C read with Rule 10B(1)(e) deals with Transactions Net Margins Method (TNMM) and it refers to only net profit margin realized by an enterprise fro
If all speculative transactions will be claimed as hedging transactions, very purpose behind the provisions of section 73 not permitting set off of speculative loss against business income will become redundant.
The Tribunal held that income earned by the taxpayer on sale of factory building, plant and machinery although not taxable as “Profit and gains of business or profession” was in the nature of income of business though assessed as capital gains and he
The CIT contended that there was no specification of assets, such as know-how, patents, copyrights, trademarks, licences, franchises or any other business or commercial rights of similar nature, which was represented by the said goodwill. Further, th
In the case of DHL Express (India) P Ltd. v. ACIT [SA No. 119/Mum/2010], dated 19 November, 2010, the Mumbai Income Tax Appellate Tribunal (
Premium paid in excess of the face value of the security held under ‘Held to Maturity’ (‘HTM’) category which has been amortised over the period remaining till maturity is allowable – rules Mumbai Tax Tribunal
Whether in computing the deduction under section 80-IA(8), for the purpose of determining the inter divisional notional transfer price, the market price of the power generated should be taken as the price of power purchased from independent power sup
The Tribunal observed that a contribution to approved superannuation fund is deductible in principle as long as the quantum of the said contribution does not exceed the prescribed limits specified in Rule 87 and 88 of the Income-tax Rules. The limi
It is pertinent to note that the Central Board of Direct Taxes had issued Circular No. 7/2007 dated 23 July 2007 which provides the procedure and circumstances for refund of tax deducted at source under section 195 of the Act to the tax deductor. How
The Tribunal has once again reiterated the principle that interest on fixed deposits kept as margin with banks is effectively connected with the business and would be taxable as business income. Furthermore, the Tribunal held that the direct expenses
