Income Tax : Learn all about the Income Tax Appellate Tribunal. Find out about appealable orders, time-limits, and the composition of the Tribu...
Income Tax : It is often seen that some Appellate orders in Vat/Income Tax/Excise/Service Tax are accepted by the Administrative Authorities wh...
Income Tax : The Income-tax department can tax even a payment made to a foreign entity outside India, if the transaction has a business connect...
Income Tax : The Mumbai Bench of the Income-tax Appellate Tribunal (‘Tribunal’) in the case of T Two International Pvt. Ltd., Tara Jewels E...
Income Tax : The Supreme Court will decide whether the interest paid on overdues to the Department of Telecom (DoT) can be treated as operating...
Income Tax : The government is likely to challenge the Income Tax Appellate Tribunal ruling on Bofors case in the Delhi High Court for its rema...
Income Tax : the following Members of the Tribunal are hereby transferred in public interest, in the same capacity, to the Bench/es of the Inco...
Income Tax : Concerned over Rs 38,000 crore in tax revenue being locked up in legal disputes, Finance Minister Pranab Mukherjee today asked the...
Income Tax : Over Rs 12,000 crore in tax demands was locked on account of disputes, pending resolution at various courts, as on June 30, 2010, ...
Income Tax : In the cited case, ITAT held that the Assessing Officer does not have power to embark upon the fresh enquiry with regard to the en...
Income Tax : In case of JCIT vs. Riddhi Siddhi Gluco Biols Ltd. The Ahmedabad tribunal has held that Interest free funds available with assess...
Income Tax : In case of ITO VS. M/s.Testree Solutions Pvt. Ltd, ITAT Bangalore held that the export proceeds received after the expiry of the p...
Income Tax : In the case of DCIT vs. M/s. Vaghasia Associates, ITAT Ahmedabad held that merely because some estimated labour payment was writte...
Income Tax : In case of ACIT vs. M/s. Prasad Machinery Pvt. Ltd. (ITAT Ahmedabad) assessee was owner of factory building. It allotted certain ...
Income Tax : CBDT raises monetary limits for tax appeals: Rs. 60 lakh for ITAT, Rs. 2 crore for High Court, and Rs. 5 crore for Supreme Court, ...
CBDT raises monetary limits for tax appeals: Rs. 60 lakh for ITAT, Rs. 2 crore for High Court, and Rs. 5 crore for Supreme Court, to reduce litigation.
Learn all about the Income Tax Appellate Tribunal. Find out about appealable orders, time-limits, and the composition of the Tribunal.
In the cited case, ITAT held that the Assessing Officer does not have power to embark upon the fresh enquiry with regard to the entries made in the books of accounts of the Company when the accounts of an assessee Company is prepared in terms of Part II Schedule VI
In case of JCIT vs. Riddhi Siddhi Gluco Biols Ltd. The Ahmedabad tribunal has held that Interest free funds available with assessee was much more than the interest free loan given by the assessee. A.O made proportionate disallowance merely on the presumption that the proportionate borrowed money must have been utilized for investment in capital work-in-progress. Relying on decision
In case of ITO VS. M/s.Testree Solutions Pvt. Ltd, ITAT Bangalore held that the export proceeds received after the expiry of the period of six months from the end of the relevant previous year was to be allowed as a deduction u/s 10A .
In the case of DCIT vs. M/s. Vaghasia Associates, ITAT Ahmedabad held that merely because some estimated labour payment was written on the projected profit & loss account, the addition for unexplained expenditure cannot be made.
In case of ACIT vs. M/s. Prasad Machinery Pvt. Ltd. (ITAT Ahmedabad) assessee was owner of factory building. It allotted certain space therein to its sister concern for enabling it to carry on their business in lieu of charging rent.
In case of M/s. AT & T Global Business Services India Pvt.Ltd. VS. ITO , assessee-company, engaged in business of software development and providing application services to its AE. TPO on basis of mean margin earned by his own set of comparables
It is often seen that some Appellate orders in Vat/Income Tax/Excise/Service Tax are accepted by the Administrative Authorities while in other SIMILAR matters Appeals are filed in the Higher Forums i.e. Tribunals/High Courts. Are these arbitrary actions of the Administrative Officials justifiable?
From the above second proviso to Section 92C(2), it is evident that if the variation between the arm’s length price and the price at which international transaction was actually undertaken does not exceed the specified percentage, then only the price at which the international transaction has actually been undertaken shall be deemed to be arm’s length price. Thus, the benefit of tolerance margin would be available only if the variation is within the tolerance margin. Once the variation exceeded the tolerance margin, then there would be no benefit even up to tolerance margin. Then, the ALP as worked out under Section 92C(1) shall be taken as ALP without any benefit of tolerance margin.
