Income Tax : Read the full text of the ITAT Delhi order on Cricket Australia vs. ACIT (International Taxation). Analysis includes why license f...
Income Tax : Delhi ITAT rules in Ares Diversified Vs ACIT that rejection of belated objections by DRP does not extend the limitation for passin...
Income Tax : Read about Bombay High Courts decision upholding ITAT's order directing Vodafone India to deposit Rs.230 crores to stay income tax...
Income Tax : Read the full text of the Delhi ITAT order on Denso (Thailand) vs ACIT, discussing tax liability for technical services under Indi...
Income Tax : ITAT emphasized that under the accrual system, provisions for outstanding expenses can indeed be recognized based on estimates and...
Read the full text of the ITAT Delhi order on Cricket Australia vs. ACIT (International Taxation). Analysis includes why license fees from live cricket match transmissions held in Australia are not considered royalty under Indian tax laws.
Delhi ITAT rules in Ares Diversified Vs ACIT that rejection of belated objections by DRP does not extend the limitation for passing final assessment U/s 144(4).
Read about Bombay High Courts decision upholding ITAT’s order directing Vodafone India to deposit Rs.230 crores to stay income tax demands, analyzing the legal implications and challenges faced.
Read the full text of the Delhi ITAT order on Denso (Thailand) vs ACIT, discussing tax liability for technical services under India-Thailand DTAA, absence of FTS clause, and PE considerations.
ITAT emphasized that under the accrual system, provisions for outstanding expenses can indeed be recognized based on estimates and do not require exact certainty at the time of accrual. The fact that the statutory auditors had approved the financial statements without qualification further supported Culver Max’s position that these provisions represented ascertained liabilities within the framework of accrual-based accounting.
Delhi High Court judgment on GE Capital vs. DCIT, distinguishing under-reporting and misreporting as separate offenses, resulting in quashed penalty. Full text analysis.
Guarantee commission charges received by a foreign parent company from its Indian subsidiaries were taxable in India, not as interest but as “other income” under Article 23(3) of the DTAA.
In the case of Salesforce.com Singapore Pte Ltd. vs ACIT, ITAT Delhi ruled that receipts from CRM services aren’t taxable in India as royalty or FTS under the Income-tax Act or India-Singapore DTAA.
ITAT Delhi dismisses DCIT’s appeal against DLF Urban Pvt. Ltd. TPO failed to apply industry filter for ALP of interest, resulting in the deletion of Rs. 6.29 crores addition.
Assessee can’t be obstructed from availing of the benefits of the Direct Tax Vivad se Vishwas Act, 2020 (DTVSV Act) even where the time limit for an appeal had not expired as DTVSV Act aspired to finally free the tax arrears locked in the litigation combat for ages and ultimately ensures timely collection of tax.
