ITAT Judgment contain Income Tax related Judgments from Income Tax Appellate Tribunal Across India which includes ITAT Mumbai, Chennai, Delhi, Kolkutta, Hyderabad etc.
Income Tax : ITAT Special Bench held that omission of scrutiny category in a Section 143(2) notice is a procedural defect curable under Section...
Income Tax : ITAT held section 35D(2)(c) applies only to companies and upheld disallowance of REIT's claim for IPO and listing expense amortisa...
Income Tax : Article examines whether the MLI Principal Purpose Test has domestic effect under Section 90(1) following Nestlé SA and Sky High ...
Corporate Law : The article argues that failure to comply before the AO or CIT(A) can lead to adverse assessments, as higher forums generally cann...
Income Tax : ITAT held that Section 54 exemption must be examined separately for each residential house sold. Aggregating gains from multiple t...
Income Tax : ITAT Bangalore restored the appeal after holding that mere upload of an order on the ITBA portal is not valid service under Sectio...
Income Tax : ITAT Bangalore held Section 2(47)(v) inapplicable as the JDA did not satisfy Section 53A conditions, deleting capital gains for AY...
Income Tax : The issue concerns massive backlog in ITAT caused by unfilled positions and delayed appointments. The intervention highlights that...
Income Tax : A representation seeks doubling the SMC threshold due to inflation and higher dispute values. The key takeaway is that increasing ...
Income Tax : The tribunal held that a gift deed alone cannot establish legitimacy under Section 68. It directed fresh scrutiny of the donor’s...
Income Tax : Mumbai ITAT held sections 234B and 234C interest must be excluded from tax effect, dismissing the Revenue's appeal as below the CB...
Income Tax : Mumbai ITAT deleted a ₹6.50 lakh section 68 addition, holding repayment of an earlier bank-transferred loan cannot be treated as...
Income Tax : ITAT Bengaluru deleted ad hoc commission and interest disallowances, holding Section 40A(2)(b) inapplicable to interest paid to a ...
Income Tax : Mumbai ITAT condoned a 917-day delay and directed that bogus purchase addition be limited to the gross profit element where sales ...
Income Tax : Mumbai ITAT restored section 12AB registration and 80G approval applications for fresh adjudication after finding relevant aspects...
Income Tax : ITAT Pune allowed rectification under Section 254(2), correcting factual errors and granting Section 54EC deduction of ₹1 crore ...
Income Tax : The ITAT Delhi has revised its hearing notice protocols. Physical notices will now be sent only once, with subsequent dates availa...
Income Tax : ITAT Chandigarh held that ITO Ward-3(1), Chandigarh had no jurisdiction to issue notice to an NRI and hence consequently the asses...
Income Tax : Central Government is pleased to appoint Shri G. S. Pannu, Vice-President of the Income Tax Appellate Tribunal, as President of th...
Income Tax : Ministry of Finance notified rules for appointment of members in various tribunals on 12.02.2020 in which practice of judicial and...
M/s. Blue Yonder India Private Limited, (Formerly JDA Software India Private Limited) Vs DCIT (ITAT Bangalore) E-INFOCHIPS LIMITED- The Annual Report of e-Zest Solutions Limited for assessment year 2010-2011 (placed at page 527 to 534 of the paper book) clearly demonstrates that it is engaged in end to end product development, including product design and […]
Bain & Company India Private Ltd. Vs DCIT (ITAT Delhi) We find the AO in the instant case disallowed the provision of professional cost amounting to Rs. 94,97,000/- debited to the profit and loss account on the ground that the assessee could not substantiate the basis for making the said provision. There was no invoice […]
Assessee made the detailed submissions inter alia contending that the provision of section 194H, 194C, 194J were not applicable to the case because the payment was not for any contractor of services or work, there was no relationship of agency.
DCIT TDS Vs Reliance Communications Ltd. (ITAT Mumbai) Roaming charges paid by the assessee to the other telecom service provider are not in the nature of ‘fee for technical services’ no TDS under section 194J is liable to be deducted. Once there is no liability for deducting tax at source, question of charging interest under […]
DCIT Vs Convergys Customer Management Group Inc. (ITAT Delhi) It is mandatory for all taxpayers, without exception, to obtain an independent accountant’s report in respect of all international transactions between associated enterprises or specified domestic transactions. The report has to be furnished by the due date of the tax return filing. Even if it is […]
Bank of India Vs JCIT (ITAT Mumbai) Conclusion: PCIT rightly directed Bank of India’s case to TPO for determination of arm’s length price (ALP) in relation to international transactions and specified domestic transactions under revision proceedings as it was binding on AO as per the CBDT Circular in force at that point of time under […]
Reopening of assessment under section 147 was not justified when there was no evidence to show that there was escapement of income due to failure on the part of assessee to disclose fully and truly all material facts necessary for assessment.
The issue under consideration is whether the Income received for sale of specialized software and maintenance and support services is considered as ‘Royalty’ as per India-Finland Tax Treaty?
The issue under consideration is whether the TDS u/s 194I is applicable on the rent if the accommodation services were taken on a casual basis?
The issue under consideration is whether the Payment towards placement services is covered under technical service and TDS u/s 195 is applicable on the same?
