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...
ITAT Delhi held that statue doesn’t empower the Assessing Officer to withdraw or modify or substitute the assessment order passed under Section 143(3) of the Income Tax Act with another assessment order.
ITAT Delhi held that the receipts from centralised service income are not taxable as Fees for Technical Services (FTS)/ Fees for included Services (FIS) under Article 12(4)(a) of India-USA DTAA.
ITAT Mumbai’s decision in case of DCIT vs KEC International Limited, where a 0.6% arm’s length rate was established for corporate guarantee fees, influencing future transfer pricing adjustments.
ITAT Delhi held that as Permanent Establishment (PE) exists, interest income being connected to the PE, has to be treated as business profit under Article 7 of the treaty. Accordingly, expenses incurred has to be set off against the interest income.
ITAT Mumbai held that FCCB i.e. Foreign Currency Convertible Bond expenses included as part of FCCB premium expenses is allowable.
ITAT Chennai held that additions made towards disallowance u/s. 14A r.w.r. 8D of the I.T. Rules, 1962 to book profit computed u/s. 115JB(2) of the Income Tax Act is unsustainable.
ITAT Mumbai held that disallowance u/s 14A untenable as AO has mechanically applied rule 8D without having recorded his satisfaction or examining the nature of investments whether they have yielded any exempt income or not.
ITAT Bangalore held that expenditure towards Employees Stock Option Plan (ESOP) is allowable deduction u/s 37 of the Income Tax Act.
ITAT Ahmedabad held that draft assessment order u/s 143(3) read with section 144C of the Income Tax Act passed on a non-existent company is null and void.
ITAT Mumbai held that provisions of Chapter X cannot be invoked for making a TP adjustment in case of Advertisement, marketing and promotion (AMP) expenses.
