Income Tax : The reliance has been placed on the decision of Hon’ble Allahabad High Court in the case of CIT Vs. M/s MT Builders Pvt. Ltd., (...
Income Tax : The assessee company is engaged in real estate business. It paid cash advance for purchasing a plot and reflected it in balance sh...
Income Tax : AO made the disallowance by invoking the provisions of section 40A(2) of the Act, however nothing was brought on record on the bas...
Income Tax : The reopening has basically been done for two reasons – the first one being the alleged difference between Unsecured Loans from ...
Income Tax : In the present case also the notice u/s 148 of the Act was issued on 31.03.2010 in the name of the deceased assessee and claimed t...
Service Tax : Tribunal held that the service provided by appellant was not in relation to agriculture. Further appellant’s claim that service ...
Service Tax : In the entirety of the show cause notice there is not a single assertion proposing to levy and collect service tax on the basis o...
Regarding the treatment of Arranger fees as fees for technical services, we find that the ld. CIT(A) had treated it to be in the nature of service fee for managing and arranging the finance and, hence, it is the consideration for rendering managerial and consultancy services.
In our conclusion, neither the payment of license fees nor the management charges, falls within the ambit and purview of section 44C and, accordingly, the nature of adjustment to the total income for the purpose of disallowance is not required. Thus it is held that license fees and management charges do not fall in the nature of head office expenses u/s.
