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Income Tax : Delhi ITAT allows Sanco Holding, a Norwegian company, to compute income from bareboat charter of seismic vessels under Article 21(...
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Income Tax : We have attached a file in excel format. The file contains the format of various details which normally assessing officer asks As...
Income Tax : ITAT Delhi held legal services are not FTS under Section 9(1)(vii) and directed partner-wise DTAA examination. FTS addition was de...
Income Tax : ITAT Mumbai deleted a Section 69 addition after finding documentary evidence established joint ownership, source of funds, and ear...
Income Tax : ITAT Mumbai quashed reassessment after finding no Section 143(2) notice and that the AO issued a final order disguised as a draft ...
Income Tax : ITAT Surat held that delayed filing of Form 10B is a procedural lapse and remanded the matter after directing the AO to consider t...
Income Tax : ITAT Delhi held that interest and dividend earned from co-operative banks qualify for deduction under Section 80P(2)(d). Totgar's ...
Income Tax : Instruction No.1/2015 Clarification regarding applicability of section 143(1D) of the Income-tax Act, 1961- Vide Finance Act, 2012...
The Karnataka High Court held that revisional powers under Section 263 cannot be exercised where the Assessing Officer has adopted one of the possible legal views. The Commissioner’s revisional order and the Tribunal’s order were quashed.
The ITAT Mumbai held that the doctrine of merger did not bar revision under Section 263 because the applicability of Section 50C was never considered during the reassessment or appellate proceedings. It upheld the revision while directing fresh consideration of the property’s valuation through the prescribed statutory mechanism.
The ITAT Kolkata held that electricity supplied by captive power plants should be benchmarked using the tariff charged by State Electricity Boards to industrial consumers for computing deduction under Section 80-IA. It upheld deletion of the transfer pricing adjustment by following Supreme Court and Calcutta High Court rulings.
The ITAT Delhi held that an appeal against an assessment order under Section 143(3) was not maintainable where no fresh additions or adverse findings were made. It ruled that the taxpayer’s grievance related to the earlier Section 143(1) order.
The ITAT held that CSR expenditure disallowed under Section 37(1) does not automatically bar deduction under Section 80G where statutory conditions are fulfilled. It allowed the deduction for donations made to an eligible Section 80G-registered trust.
The ITAT Chennai held that exemption under Section 10(23FBA) cannot be denied merely by reclassifying investment returns as business income without proper analysis. It found that the Assessing Officer failed to apply recognised tests for determining the nature of income.
The ITAT held that foreign exchange gains arising from realization of export proceeds from services rendered to associated enterprises are operating in nature for transfer pricing purposes. It directed verification by the Assessing Officer and corresponding computation of the arm’s length margin.
The ITAT Delhi held that the assessee could not claim deduction under Section 54 for the first time before the Tribunal when it had neither been claimed in the return nor during assessment proceedings. The Tribunal also upheld the remand of the Section 50C issue to the Assessing Officer.
ITAT Delhi held that cash deposits recorded in audited books and linked to disclosed business transactions could not be taxed under Section 69A. The Tribunal deleted the ₹5.60 crore addition after finding the source of deposits was explained.
ITAT Mumbai held that Compulsorily Convertible Debentures could not be treated as equity merely to deny interest deductions. The Tribunal deleted the ₹76.45 crore transfer pricing adjustment arising from such recharacterization.