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Receipts on sale of software not taxable as royalty

Case Name : IBM Singapore Pte Ltd. Vs DCIT (ITAT Banglore)
Appeal Number : ITA No.3229/Bang/2018
Date of Judgement/Order : 23/08/2021
Related Assessment Year : 2014-15
Courts : All ITAT (14947) ITAT Bangalore (1081)
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HC stays Section 263 order as Mandatory twin pre conditions were prima facie not fulfilled

Case Name : Karan Jain Vs. The Union Of India And 3 Ors (Gauhati High Court)
Appeal Number : WP(C)/3999/2021
Date of Judgement/Order : 19/08/2021
Related Assessment Year :
Courts : All High Courts (13939) Guwahati High Court (119)
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HC allows expense on Foreign Education & Training of Partner related to Business who continued after education

Case Name : Aswathanarayana & Eswara Vs DCIT (Madras High Court)
Appeal Number : Tax Case Appeal No. 409 of 2009
Date of Judgement/Order : 30/03/2021
Related Assessment Year : 1999-2000
Courts : All High Courts (13939) Madras High Court (1758)
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Section 263 Order of AO must be erroneous & prejudicial to interest of revenue

Case Name : CMJ Breweries Private Limited Vs Union of India (Gauhati High Court)
Appeal Number : Case No. : WP(C)/3986/2021
Date of Judgement/Order : 19/08/2021
Related Assessment Year :
Courts : All High Courts (13939) Guwahati High Court (119)
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HC stays section 148 notice issued after 31.03.2021 as per omitted provisions

Case Name : Vijay Kumar Devnani Vs ITO and Anr. (Madhya Pradesh High Court)
Appeal Number : WP No. 15243 of 2021
Date of Judgement/Order : 18/08/2021
Related Assessment Year :
Courts : All High Courts (13939) Madhya Pradesh HC (176)
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HC stays section 148 notice issued after 31st March, 2021

Case Name : Sai Kripa Farms Vs ITO (Madhya Pradesh High Court)
Appeal Number : WP No. 15207 of 2021
Date of Judgement/Order : 18/08/2021
Related Assessment Year :
Courts : All High Courts (13939) Madhya Pradesh HC (176)
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Deemed dividend not attracted on Loan Taken on interest

Case Name : DCIT Vs Heilgers Development & Construction Company Pvt. Ltd (ITAT Kolkata)
Appeal Number : I.T.A. Nos. 1922 & 1923/Kol/2019
Date of Judgement/Order : 18/08/2021
Related Assessment Year : 2015-16 & 2016-17
Courts : All ITAT (14947) ITAT Kolkata (1034)
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Membership fee & legal fund paid to FIMI allowable as Business Expense to Mining Company

Case Name : Zeenath Transport Company Vs ACIT (ITAT Bangalore)
Appeal Number : ITA No. 1780-1782/Bang/2018
Date of Judgement/Order : 18/08/2021
Related Assessment Year : 2012-13 to 2014-15
Courts : All ITAT (14947) ITAT Bangalore (1081)
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Reopening for accommodation entry based on inquiries & Investigation report was valid: HC

Case Name : Sanjay Baulal Surana Vs ACIT (Gujarat High Court)
Appeal Number : R/Special Civil Application No. 20501 of 2019
Date of Judgement/Order : 11/08/2021
Related Assessment Year : 2013-14
Courts : All High Courts (13939) Gujarat High Court (1139)
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Management Consultancy cannot be considered as technical consultancy

Case Name : Pramod Lele Vs ITO (ITAT Mumbai)
Appeal Number : ITA No. 4306/Mum/2019
Date of Judgement/Order : 12/08/2021
Related Assessment Year : 2015-16
Courts : All ITAT (14947) ITAT Mumbai (3583)
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