Income Tax : A detailed overview of limitation periods prescribed under the Income-tax Act reveals how missing statutory deadlines can lead to ...
Income Tax : Understand Section 44AD of the Income Tax Act: presumptive business income, eligibility, turnover limits, and tax implications for...
Income Tax : Learn about Section 44AD, a simplified method to compute business income, excluding some entities. Thresholds and tax implications...
Income Tax : Sunset date for claiming Income Tax exemption for SEZs – Time to further extend the sunset date mentioned under Section 10AA...
Income Tax : Section 10A of the Income Tax Act, 1961 (the Act for short) deals with special provision in respect of newly established undertaki...
Income Tax : FM: Role of IT Sector is Crucial in Order to Promote E-Governance for Empowering Citizens; to Promote the Inclusive and Sustainabl...
Income Tax : Infosys Technologies Ltd. Tuesday said it will appeal against an order from the income tax department seeking more than 4 billion ...
Income Tax : Supreme Court held that Section 10A is a deduction provision, but the deduction must be allowed while computing the eligible under...
Income Tax : Transfer pricing principles dictate that a captive, risk-mitigated service provider could not be benchmarked against full-fledged,...
Corporate Law : NCLT Amaravati held that the corporate debtor's OTS proposals constituted acknowledgments of debt, giving rise to a fresh limitati...
Income Tax : The Karnataka High Court held that where the Revenue had consistently accepted the same interest rate in earlier and subsequent as...
Income Tax : The Tribunal held that delayed filing of Form 10-IC should not defeat the assessee's substantive right to opt for the concessional...
Income Tax : As per section 10A(4) of Income Tax Act, 1961, profits derived from export of articles or things or computer software shall be amo...
Income Tax : Circular No. 14/2014-Income Tax CBDT had issued Circular No.12/2014 dated 18th July, 2014 to clarify that mere transfer or re-dep...
Income Tax : Circular No. 12/2014-Income Tax Section 10AA of the Income-tax Act, 1961, inter-alia, provides for deduction in respect of the pr...
Income Tax : A clarificatory Circular No. 01/2013 dated 17.01.2013 was issued by CBDT to address various contentious issues leading to tax disp...
Income Tax : A clarificatory Circular No. 01/2013, dated 17-1-2013 (hereinafter referred to as 'Circular') was issued by CBDT to address variou...
Assessee was entitled to alternative claim of exemption on export of software and IT enabled service under section 10A by following the decision in case of 2020 (113) taxmann.com 74 (SC) [Commissioner of Income-Tax III v. Mphasis Ltd.]
AO did conduct an enquiry, called for details, the details were produced and thereafter, the assessment was completed. Therefore, the finding of the PCIT was erroneous, consequently, assumption of jurisdiction under Section 263 was not sustainable. Also, there was no requirement in law to maintain separate books of account for claiming deduction under section 10A. However, since the deductions under these sections were available only to the eligible units, AO might call for such details or information pertaining to different units to verify the claim and quantum of exemption, if so required.
Amount of income which qualifies for deduction is the profits of the business of the undertaking and not any income earned by assessee de hors the business of the undertaking. If the relevant items of income are held to be falling under the head `Income from other sources’, the same will not qualify for deduction under sectio 10A, 10AA.
The issue under consideration is whether denial of claim of deduction u/s 10AA of the Act on transfer pricing adjustment made by the assessee voluntarily is justified in law?
Tata Consultancy Services Ltd. Vs Addl. CIT (ITAT Mumbai) As could be seen, while the Assessing Officer has disallowed assessee’s claim of foreign tax credit in respect of income exempt under section 10A/10AA of the Act on the reasoning that only such income which is subjected to tax in both the countries would qualify for […]
Preludesys India Ltd. Vs. ACIT (Madras High Court) The first aspect that has to be considered is as to whether the Income Tax Act, 1961 deals with the concept of a ‘deemed export’. This position has been clearly explained by the High Court of Karnataka both in the case of Tata Elxsi Ltd., and in […]
whether the 1st proviso of section 92C(4) is triggered when the income computation for deduction u/s 10AA is enhanced only in the computation of income and no such entries are made in the books of account?
Mindtree Ltd Vs. ACIT (Karnataka High Court) Thus, the Commissioner of Income Tax (Appeals) has recorded a categorical finding that assessee is engaged in the development of computer software, which is exported outside India. The aforesaid finding has not been set aside by the Tribunal. Therefore, in view of Explanation 2(iii) to Section 10B of […]
CIT Vs. Sankhya Technologies Pvt Ltd. (Madras High Court) It has been brought to the notice of this Court that there is a judgment of the Full Bench of the Karnataka High Court, to which one of us (Dr.Vineet Kothari, J.) was a party, in which the Full Bench has held that the interest on […]
The issue under consideration is whether disallowance of relocation expenses u/s 40(a)(i) of the Act and non granting of tax deducted at source with respect to that expense is justified in law?