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 Bangalore held that as professional and consultation charges & purchase of fixed assets are capitalized in the books of accounts, it should not be considered for computation of proportionate TP adjustment.
ITAT Hyderabad held that FCCDs are debt hence interest paid/ payable on FCCDs in to be computed by applying LIBOR plus 200 basis points.
ITAT Delhi held that payment received in the nature of Business Profit cannot be brought to tax in India in absence of Permanent Establishment in India.
Telangana High Court held that writ jurisdiction under Article 226 of the Constitution of India not invocable as adequate and effective alternative remedy under Section 144C of the Act by way of filing objections before the Dispute Resolution panel available to the petitioner.
Final order passed by AO is beyond limitation period provided u/s 144C of Income Tax Act, hence, same is liable to be declared as null & void
ITAT Rajkot held that Partner’s/Director’s nationality will not suffice the company’s residency as the company is incorporated in UAE and is managed and controlled only in UAE. Thus, it is a tax resident of UAE and, therefore, treaty between India and UAE (DTAA) is applicable
ITAT Delhi held that when the transaction between the assessee and its Indian AE is found to be at arm’s length, no further attribution of profit can be made to the dependent agent PE in India.
ITAT Delhi held that royalty payment and R&D cess on royalty is interlinked. As royalty payment is allowed as revenue expenditure, R&D cess is also allowable as revenue expenditure.
ITAT Mumbai held that income earned from offshore supply of escalators and elevators is not taxable in India as assesse didn’t carried out any operations in India.
ITAT Mumbai held that the assessment order passed in variation of the procedures prescribed u/s. 144B of the Income Tax Act would render the assessment order as non est.
