Income Tax : Taxpayers face challenges when assessment orders don’t reflect DRP directions. Misalignments lead to disputes, rectification iss...
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Income Tax : ITAT Chennai held that salary received for international assignment which is subjected to tax in UK could not be taxed in India. A...
Corporate Law : Karnataka High Court held that since rectification application was filed before passing of final assessment order, DRP ought to ha...
Income Tax : ITAT Delhi rules that subscription fees from cloud services are not taxable as royalty under the India-Ireland DTAA. ...
Income Tax : ITAT Delhi held that damages are compensation received is a capital receipt, however, interest on damages is to be treated as reve...
Income Tax : Distribution revenue received by Turner Broadcasting System Asia Pacific, Inc. ( TBSAP ), a U.S.-based company, from its Indian af...
Taxpayers face challenges when assessment orders don’t reflect DRP directions. Misalignments lead to disputes, rectification issues, and relief from appellate authorities.
ITAT Chennai held that salary received for international assignment which is subjected to tax in UK could not be taxed in India. Accordingly, claim of the assessee allowed. The assessee being non-resident individual filed return of income declaring income of Rs.2295/- and claiming refund of Rs.10.08 Lacs.
Karnataka High Court held that since rectification application was filed before passing of final assessment order, DRP ought to have waited till disposal of rectification application. Thus, final assessment order liable to be set aside.
ITAT Delhi rules that subscription fees from cloud services are not taxable as royalty under the India-Ireland DTAA.
ITAT Delhi held that damages are compensation received is a capital receipt, however, interest on damages is to be treated as revenue receipt hence the same is taxable.
Distribution revenue received by Turner Broadcasting System Asia Pacific, Inc. ( TBSAP ), a U.S.-based company, from its Indian affiliate was not taxable as “royalty” under the Income Tax Act, 1961, or the India-U.S.
Assessee claimed to have receiving services in the fields of technology, Services, Risk Information Management, Head quarter, Technology Services/back office support services/treasury/regional headquarter services etc.
Alena Cyprus had also filed its return of income in India for the AY 2018-19 wherein LTCG of Rs. 80,86,75,225 arising from sale of shares to assessee were declared exemption claimed under Article 13 of the India-Cyprus DTAA.
Thereafter, the petitioner lodged objections on 10.03.2022. The impugned Draft Assessment Order was issued thereafter on 30.03.2022 u/s. 144C of the Act. Being aggrieved, the present writ is filed.
ITAT Mumbai held that when the reserve/provisions created in the year where the assessee has increased the book profit u/s. 115JB of the Act, the assessee is entitled to reduce the amount withdrawn from such reserve if the same is credited to the P & L account in that year.
