Income Tax : The article explains remedies available after adverse tax orders under scrutiny and reassessment. The key takeaway is that choosin...
Income Tax : The Court clarified that mere pendency of information exchange requests under DTAA cannot justify continuing a Look Out Circular. ...
Income Tax : A surge in Section 143(2) notices was triggered by the June 2025 limitation deadline. This explains why cases were picked and how ...
Income Tax : The Tribunal ruled that penalty under Section 271A cannot be levied merely because books were rejected and income was estimated. S...
Income Tax : The ITAT held that an assessment completed before receiving the DVO report under section 50C(2) is invalid. All additions and disa...
Income Tax : Delhi ITAT allows Sanco Holding, a Norwegian company, to compute income from bareboat charter of seismic vessels under Article 21(...
Income Tax : It has been observed that in many cases an assessee may wish to make a claim which was not made in the return of income filed unde...
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 : Tribunal observed that the Assessing Officer failed to establish any mismatch in stock, sales, or accounting records before making...
Income Tax : ITAT Hyderabad held that constituent members of a JV or Consortium can claim deduction under Section 80IA(4) when they actually ex...
Income Tax : The Tribunal found that full payment, TDS deduction, and transfer of possession established completion of the transaction for capi...
Income Tax : ITAT Rajkot held that cash deposits made during demonetization were fully supported by audited books of account, cash books, and b...
Income Tax : The Hyderabad ITAT held that purchases cannot be treated as bogus merely because the supplier failed to respond to a notice under ...
Income Tax : Instruction No.1/2015 Clarification regarding applicability of section 143(1D) of the Income-tax Act, 1961- Vide Finance Act, 2012...
The Tribunal refused to condone an 840-day delay in filing an appeal where the assessee claimed the Chartered Accountant failed to inform about the assessment order. It held that a taxpayer must remain vigilant about proceedings and cannot shift full responsibility to the counsel.
The Tribunal found that the taxpayer had filed Form 68 seeking immunity from penalty but the request was rejected without due process. It directed the Assessing Officer to re-examine the immunity claim in accordance with law.
ITAT ruled that addition under Section 68 requires a fresh credit in the books during the relevant year. Where loans represent opening balances from earlier years, they cannot be treated as unexplained income.
ITAT Pune held that creation of artificial intangible asset i.e. goodwill in intra-group merger is merely a colourable transaction out between the Holding Company and the subsidiary company. Accordingly, depreciation claimed thereon deserves to be disallowed.
The Tribunal upheld deletion of a Section 14A disallowance after noting that the taxpayer did not earn any exempt income in the relevant assessment year. The ruling reiterates that Section 14A cannot be invoked in the absence of exempt income.
The Tribunal removed the transfer pricing addition on delayed receivables from associated enterprises, holding that the company’s profit margins exceeded comparable companies and interest was already embedded in pricing.
The ITAT relied on surrounding circumstances, documentary evidence, and the principle of human probabilities to conclude that cash consideration was paid in a land transaction. The Tribunal confirmed the addition of unaccounted sale consideration as short-term capital gains.
The Court clarified that mere pendency of information exchange requests under DTAA cannot justify continuing a Look Out Circular. Where assessments are quashed and no tax liability exists, indefinite travel restriction is unconstitutional.
The Tribunal ruled that exemption under Sections 11 and 12 cannot be denied by aggregating separate shareholdings to invoke Section 13(2)(e). It held that no office bearer individually held substantial interest, making the addition unsustainable.
Bain & Company Vs D/ACIT (ITAT Delhi) The appeal before the Income Tax Appellate Tribunal (ITAT), Delhi arose from a final assessment order dated 18 December 2024 passed by the Deputy/Assistant Commissioner of Income Tax (International Tax), Gurgaon under Section 143(3) read with Section 144C(13) of the Income-tax Act, 1961. The assessee is a foreign company […]
