Income Tax : Smt. Ranjana Kumari/Kalta Vs DCIT/ACIT (Central) (ITAT Chandigarh) The appeals involved three assessees belonging to the Kalta Gro...
Income Tax : Understand the statutory time limits for issuing income-tax notices and completing assessments under the Income-tax Act. The guide...
Income Tax : Learn the updated provisions governing rectification, assessments, reassessments, and appeals under the Income-tax Act. This guide...
Income Tax : Learn how different types of income tax assessments are conducted under the Income-tax Act. The FAQs explain assessment procedures...
Income Tax : Section 154 permits rectification of mistakes apparent from the record in assessment orders, intimations, and TDS/TCS processing s...
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 : 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 court held that revision under section 263 requires independent satisfaction by the PCIT. Acting merely on the Assessing Officer’s view renders the revision order invalid.
The issue was whether high-turnover companies can be compared with a smaller software service provider. The Tribunal held that companies with disproportionately large turnover must be excluded as they distort comparability due to scale advantages.
The issue involved denial of LTCG exemption based on allegations of penny stock manipulation. The Tribunal held that without direct evidence or nexus, such additions cannot be sustained.
The Court held that reassessment based solely on an audit objection is invalid as it constitutes a change of opinion. It emphasized that previously examined issues cannot be reopened without new tangible material. The ruling reinforces limits on reassessment powers.
ITAT ruled that deduction under Section 54F can be raised during reassessment if it relates to the income under scrutiny. The case clarifies that reassessment scope includes such connected claims.
The Tribunal held that LTCG cannot be treated as bogus merely based on investigation reports. It ruled that documented transactions through banking and stock exchange channels prove genuineness.
The tribunal held that capital gains from share buyback are not taxable in India under treaty provisions. It clarified that such transactions qualify as corporate reorganisation. The key takeaway is that DTAA benefits override domestic tax provisions when more beneficial.
The ITAT clarified that Article 13(3A) applies strictly to shares and not to derivative instruments. It held that derivative gains fall under residual provisions and are taxable in the resident country. The ruling emphasizes correct interpretation of DTAA provisions.
The tribunal set aside excessive addition by recognizing both the allotment agreement and joint ownership. It directed proportionate taxation and correct valuation basis. The ruling promotes fairness in assessments.
The tribunal allowed adoption of stamp value as on the agreement date instead of registration. It held the proviso to Section 50C is retrospective as it removes hardship. This provides relief in cases of delayed registration.
