Courts: ITAT Mumbai
5,841 articlesIncome Tax
Income Tax
Persons deputed by foreign company to an Indian company cannot be considered as its PE in India when services rendered by them are independent and not under control of that company
Income Tax
Income Tax
Royalty paid by Non-resident to another Non-resident is not taxable if not related to and borne by PE in India
Income Tax
Income Tax
Any person from whom a non-resident is in receipt of any income can be treated as an agent of such non-resident: Mumbai ITAT
Income Tax
Income Tax
Section 54 Exemption on multiple sales & purchases of residential houses
Income Tax
Income Tax
Mumbai ITAT upholds per hour billing rate published by NASSCOM for a specific business segment as an external CUP in determining the arm’s length price
Income Tax
Income Tax
Payment made for computer software not Royalty and TDS u/s. 195 not applicable
Income Tax
Income Tax
Expenditure incurred on food and beverages at the guest houses maintained by the assessee near factory for employee in connection with their stay during official visits allowable
Income Tax
Income Tax
Default u/s 194C does not result in s. 40(a)(ia) disallowance if TDS paid before due date of filing ROI
Income Tax
Income Tax
Penalty sustainable on income not disclosed in Original return but disclosed in return filed after search
Income Tax
Income Tax
If brokerage offered to tax, the principal debt qualifies as a “bad debt” u/s 36(1)(vii) r.w.s. 36(2)
Income Tax
Income Tax
Even Offshore Services Are Taxable As PE Profits – ITAT Mumbai
Income Tax
Income Tax
Transfer Pricing TNMM must be applied to transaction margins and not to enterprise level margins. Adjustments must be confined to international transactions
Income Tax
Income Tax
Royalty paid by non-resident does not arise in India if there is no “economic link” between the PE and the royalty
Income Tax
Income Tax
