Courts: ITAT Mumbai
5,841 articlesIncome Tax
Income Tax
Onus is on assessee to submit relevant data which must be examined by the revenue for ALP determination by applying prescribed methods
Income Tax
Income Tax
Royalty Payments not Taxable in India Sans Economic Nexus with Permanent Establishment
Income Tax
Income Tax
Assessee to follow one of the methods prescribed and demonstrates that international transactions entered with associated enterprise are at arm’s leng
Income Tax
Income Tax
Special Bench of ITAT on taxability of loss in case of forward foreign exchange contracts
Income Tax
Income Tax
Penalty u/s 271 on disallowance u/s 40(a)(ia)
Income Tax
Income Tax
Expression ‘liable to tax’ in contracting State as used in Article 4(1) of Indo-UAE-DTAA not necessarily imply that person should actually be liable to tax in that contracting State
Income Tax
Income Tax
Provisions of section 194C not attracted to finance agreements between financing company and producers/directors of films/TV serials
Income Tax
Income Tax
AO cannot act u/s. 147 merely because he happened to change his opinion or to hold an opinion different from that of his predecessor on same set of facts
Income Tax
Income Tax
Penalty imposable under main provisions of section 271(1)(c) and there is no need to refer to any Explanations
Income Tax
Income Tax
Assessee not expected to demonstrate that contracts are not artificially split
Income Tax
Income Tax
Transfer Pricing Provision- Mere geographical contiguity of two countries need not mean similarity in economic or market conditions
Income Tax
Income Tax
Dy. Director of Income Tax (International Taxation) Vs. M/s Avaya Global Connect Ltd., (ITAT Mumbai)
Income Tax
Income Tax
Fiscally transparent partnership firm eligible for tax treaty benefits and application of “force of attraction” rule to profits indirectly attributable to PE
Income Tax
Income Tax
