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Section 144C

Latest Articles


Section 44C of Income Tax Act, 1961 Deduction of head office expenditure in case of Non-residents

Income Tax : Discover how Section 44C of the Income Tax Act, 1961, governs the deduction of head office expenses for non-resident businesses in...

July 19, 2024 906 Views 0 comment Print


Latest Judiciary


Company with Turnover 10 times of Assessee’s Cannot Be Included as Comparable: ITAT Hyderabad

Income Tax : ITAT Hyderabad directed to exclude companies having turnover of more than or less than 10 times of the turnover of the assessee fr...

August 12, 2024 156 Views 0 comment Print

Direction given by Tribunal to AO to re-examine issue cannot be disregarded: Delhi HC

Income Tax : Delhi High Court held that once the Tribunal had called upon the AO to examine the issue afresh, the said direction could not have...

August 7, 2024 219 Views 0 comment Print

Tax not leviable on LTCG earned by Mauritius company on sale of share: ITAT Delhi

Income Tax : ITAT Delhi held that long term capital gain on sale of shares in case of the assessee company, being resident of Mauritius, is not...

July 31, 2024 195 Views 0 comment Print

Receipts from Indian customers for services provided outside India relating to right to use of process not taxable: Delhi HC

Income Tax : Delhi High Court held that the receipts from Indian customers for services provided outside Indian Territory, in connection with u...

July 29, 2024 369 Views 0 comment Print

Guarantee fee to AE resulted into reduced interest rate hence TP adjustment unjustified: ITAT Ahmedabad

Income Tax : ITAT Ahmedabad held that benefit demonstrated in form of reduced interest rate on account of guarantee, thus, payment of guarantee...

July 26, 2024 135 Views 0 comment Print


Tax leviable as receipt qualifies as Fees for Technical Services as per Indo – Singapore DTAA

October 5, 2023 837 Views 0 comment Print

ITAT Delhi held that payments received by the assessee qualifies as Fees for Technical Services (FTS) under sub-clause (4) of Article 12 of Indo – Singapore DTAA and hence rightly brought to tax @10%.

ITAT deletes ALP adjustment as it falls within tolerance band of +/- 5% 

October 4, 2023 393 Views 0 comment Print

Read how ITAT Delhi deleted ALP adjustment in STEAG Energy Services vs. ACIT case, as it falls within tolerance band of +/- 5% under Section 92C(2) of Income Tax Act.

Section 271(1)(c) penalty unjustified without Income Concealment or Inaccurate Particulars

October 3, 2023 2886 Views 0 comment Print

ITAT Delhi held that imposition of penalty u/s. 271(1)(c) of the Income Tax Act unsustainable in absence of any concealment of income or furnishing inaccurate particulars of income by the assessee.

‘Non-cooperative attitude’ alone cannot justify penalties: ITAT Delhi

October 2, 2023 753 Views 0 comment Print

Explore the case of Alankit Imaginations Ltd vs. DCIT (ITAT Delhi), where penalties were challenged. Learn why a ‘non-cooperative attitude’ alone cannot justify penalties.

Once assessment order is passed Dispute Resolution Panel not empowered to give direction

September 28, 2023 2376 Views 0 comment Print

Bombay High Court held that Dispute Resolution Panel (DRP) could give directions only in pending assessment proceedings. Once assessment order is passed, DRP has not power to pass any direction.

Long term capital gain and indexation accepted for one co-owner needs to be allowed for other co-owner too

September 27, 2023 909 Views 0 comment Print

ITAT Delhi held that once long term capital gain along with cost of acquisition and indexation accepted in the hands of one of the co-owner of the property, the same needs to be allowed/ accepted for other co-owner of the property too.

ITAT Grants 30% Depreciation on Philips India’s Business-Owned Moulds

September 21, 2023 660 Views 0 comment Print

Read the full text of the ITAT Kolkata order in the case of Philips India Limited vs. ACIT regarding the grant of 30% depreciation on business-owned moulds.

Benefit of indexed cost of acquisition available based on payments dates

September 15, 2023 1479 Views 0 comment Print

ITAT Delhi held that held that benefit of indexed cost of acquisition should be available to assessee based on payments made. Accordingly, AO directed to re-compute gain.

Payment of guarantee fees to holding company for loan advanced to third party is deductible u/s. 37

September 15, 2023 603 Views 0 comment Print

ITAT Mumbai held that guarantee fees paid to holding company for loan advanced by assessee to third party is commercial/ business expediency and hence allowable as deduction under Section 37 of the Income Tax Act.

Payment towards interconnectivity utility charges from Indian customers not taxable as Royalty

September 9, 2023 909 Views 0 comment Print

ITAT Bangalore held that payments received towards interconnectivity utility charges from Indian customers / end users cannot be considered as Royalty to be brought to tax in India under section 9(1)(vi) of the Income Tax Act and also as per DTAA.

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