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Data Transmission Services did not amount to royalty in terms of Article 12 of the Indo-Thai Double Taxation Avoidance Agreement.
The issue under consideration is whether the services in relation to issuance of GDRs are covered under the provisions of Section 9(i)(vii) and whether the same liable for TDS under the provisions of Section 195 of the Act?
ITAT states that, it was not disputed that the borrowings were made in earlier years and no disallowance of interest was made in earlier years with regard to the said borrowings and utilization thereon.
The issue under consideration is whether depreciation will be levied on the intangible being CMS software? CMS, which has been developed by the assessee is computer application which supports the creation and modification of content and is often used to support multiple users working in a collaborative environment.
The issue under consideration is whether the long-term capital gain on sale of non-STT paid shares can be set off against long-term capital loss arising from STT paid shares?
Petition has been filed seeking a direction to the respondents to remove technical glitches and enable the TRACES portal so that petitioner can file its refund application for the excess Tax Deduction at Source (TDS) deposited by it.
The issue under consideration is whether the default in home loan by the owner of the property can be the reason to disallow the capital gain deduction u/s 54F of the Income Tax Act, 1961?
The issue under consideration is whether the addition made by AO u/s 14A with respect of Interest free funds is justified in law?
Krythium Solutions Private Limited Vs ACIT (ITAT Cochin) The issue under consideration is whether claiming deduction u/s 10A of the Income Tax Act through filing revised return is justified in law? ITAT states that the CBDT Circular No.14 (XL-35) dated 11.04.1955 has clarified that the revenue shall not take advantage of ignorance of the assessee […]
he Supreme Court in GKN Driveshafts (India Ltd.) v. Income Tax Officer 259 ITR 19 (SC) has clarified that when a notice under Section 148 of the Income Tax Act is issued, the proper course of action for the notice is to file a return and if he so desire, to seek reasons for issuing notices.