National Internet Exchange of India Vs ACIT (ITAT Pune) National Internet Exchange of India (NIXI) is engaged in carrying out running of internet exchange and registration of domain name. For running of internet exchange, the assessee is charging membership fees, connectivity charges, data transferred differential. For registration of domain name, the assessee the charges registration […]
Norton Lifelock Inc. Vs DCIT (ITAT Pune) The assessee sold software licenses to end users in India which was claimed as not chargeable to tax. The Revenue treated such amount as Royalty income. We thus primarily need to decide the nature of income earned by the assessee from the sale of software licenses as to […]
Income earned by assessee from sale of software, either directly to the customers in India or through Distributors or Resellers constituted its business income and not the Royalty income. As admittedly assessee did not have any Permanent Establishment in India, such income will not magnetize Indian taxation.
Explore the tax implications as Sandvik AB challenges the characterization of Training fees, testing DTAA provisions, and its application in the ITAT Pune decision.
JCIT (OSD) Vs Rohan and Rajdeep Infrastructure Pvt. Ltd. (ITAT Pune) Assessee incurred expenditure in constructing Amritsar Bus Terminal on BOT basis and to recoup the said investment, the assessee was allowed to collect add a fees from the users of the said bus terminal. In our view, the said right is business or commercial […]
Assessee also incurred expenditure in constructing Amritsar Bus Terminal on BOT basis and to recoup said investment, assessee was allowed to collect Adda fees from users of said bus terminal. The said right was business or commercial right in terms of section 32(1)(ii) and was an intangible asset, therefore, assessee was entitled to claim depreciation.
Jaya Hind Industries Limited Vs DCIT (ITAT Pune) which is used in the robotic arms forming part of high pressure die casting machines can be allowed as revenue expenditure. The factual submissions made on behalf of the appellant are that the expenditure was incurred on replacement of Gripper which is part of robotic arms forming […]
DCIT Vs Runwal Multihousing Pvt. Ltd. (ITAT Pune) we find that the assessee was regularly following the Percentage completion method by valuing the closing work-in-progress at estimated realizable price. Certain unforeseen circumstances developed. The assessee switched over from the Percentage completion method to the Project completion method by filing a revised return. It is not […]
Assessee had handed over possession of the property to M/s. V.S. K Associates in the year 2000 on receiving substantial part of consideration which constituted transfer u/s. 2(47)(v) read with section 53A of the TPA attracting taxability of capital gain in the A.Y. 2001-02. Thus, the same could not once again be taxed in the assessment year 2007-08.
Santosh Mohanlal Rathi Vs DCIT (ITAT Pune) ITAT followed Hon’ble Bombay High Court decision in the case of M/s. Nirved Traders Pvt. Ltd., Vs. DCIT (ITA No.149/2017 dated 23.04.2019) wherein the Jurisdictional High Court held that the disallowance under Section 14A of the Act read with Rule 8D(2) of the Rules cannot exceed the Assessee’s […]
