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 the amount of received in the arbitration settlement is related to project office of the assessee company in India. Accordingly, the same is taxable in India.
ITAT Mumbai held that issuance of draft assessment order along with the demand notice is in violation of provisions of section 144C of the Income Tax Act and hence bad in law.
ITAT Delhi held that assessment order passed in violation of the directions of Dispute Resolution Penal (DRP) is against the provisions of sub-section (10) and (13) of section 144C of the Act and hence liable to be quashed
Bombay High Court held that Circular No.5-2012 dated 1 August 2012 will not be applicable to the instant case pertaining to AY 2008-09. Law to be applied is the one that is in force in the relevant assessment year unless otherwise provided expressly or by necessary implication. Accordingly addition unsustainable.
ITAT Bangalore held that disallowance merely considering the provisions of section 144C(8) of the Income Tax Act without verification of details furnished by the assessee is unsustainable in law.
ITAT Delhi held that transactions relating to currency swap contracts cannot be considered to be in the nature of speculative transaction covered u/s. 43(5) of the Act. Accordingly, the same is allowable as deduction u/s. 36(1)(iii) of the Act.
ITAT Mumbai held that as per section 92CA (3A) of the Income Tax Act Transfer Pricing Officer (TPO) is required to pass an order within a period of 60 days prior to the date of completion of assessment as per section 153 of the Income Tax Act. Order passed after the date will be barred by limitation.
DSV Solutions Pvt Ltd Vs DCIT (ITAT Mumbai) There was no forwarding, not even an effort to forward, the draft assessment order to the correct address, or at least the address furnished to the Assessing Officer under proviso to rule 127(2), within the permitted time frame under Section 153 r.w.s 144C of the Income Tax […]
ITAT Delhi held that payment received from sale of software products/ licenses doesn’t fall in the nature of royalty as per Article 12(3) and as per section 9(1)(vi) and hence the same is not taxable in India.
Held that the authorities fallen in error in considering the subscription received towards cloud serviced to be royalty income
