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Section 144C

Latest Judiciary


Cricket Australia vs. ACIT: Live Transmission Fee Not Taxable as Royalty

Income Tax : Read the full text of the ITAT Delhi order on Cricket Australia vs. ACIT (International Taxation). Analysis includes why license f...

July 9, 2024 120 Views 0 comment Print

DRP’s Rejection of Belated Objections Doesn’t Extend Assessment Limitation: ITAT Delhi

Income Tax : Delhi ITAT rules in Ares Diversified Vs ACIT that rejection of belated objections by DRP does not extend the limitation for passin...

July 4, 2024 201 Views 0 comment Print

Bombay HC Upholds Conditional Stay for Vodafone, Modifies Guarantee

Income Tax : Read about Bombay High Courts decision upholding ITAT's order directing Vodafone India to deposit Rs.230 crores to stay income tax...

June 26, 2024 303 Views 0 comment Print

Delhi ITAT Rules No Tax on Technical Services to AE Without PE in India

Income Tax : Read the full text of the Delhi ITAT order on Denso (Thailand) vs ACIT, discussing tax liability for technical services under Indi...

June 20, 2024 447 Views 0 comment Print

Provision for outstanding expenses for ascertained liability allowable

Income Tax : ITAT emphasized that under the accrual system, provisions for outstanding expenses can indeed be recognized based on estimates and...

June 15, 2024 531 Views 0 comment Print


ITAT allows Section 54 Deduction Not Claimed in Original or Revised Return

August 29, 2023 729 Views 0 comment Print

ITAT Delhi permits a Section 54 deduction that wasn’t claimed in original or revised returns. The case highlights the powers of appellate authorities.

Cost reimbursement for support services taxable as Fees for Technical Services

August 24, 2023 1374 Views 0 comment Print

ITAT Mumbai held that cost reimbursement received towards providing support services is taxable as Fees for Technical Services (FTS) both under Section 9(1) (vii) of the Act as well as Article 12(4) of the Double Taxation Avoidance Agreement.

Depreciation eligible on Solar Power Plant as electricity utilized for factory operations

August 24, 2023 14733 Views 0 comment Print

ITAT Delhi held that depreciation on Solar Power Plant installed on office building which is part of factory and electricity so generated is used for factory only is allowable as per provision of law.

Addition of Offshore Supply Income to PE in India on account of loss Unjustified

August 22, 2023 549 Views 0 comment Print

ITAT Delhi held that addition on account of attributing income from offshore supplies to permanent establishment in India unjustified in case of loss.

Assessment order against a non-existing entity post amalgamation is invalid

August 22, 2023 477 Views 0 comment Print

ITAT Mumbai ruled that an assessment order against a non-existent entity (Pipal Research Analytics) is invalid. Insight into Crisil Ltd vs ACIT case.

ITAT Imposes Rs. 10,000 Cost on Appellant for not responding to notices issued by AO

August 21, 2023 582 Views 0 comment Print

ITAT Mumbai imposes Rs. 10,000 cost on Hunt International Investments LLC for non-response to notices under section 142(1). Details on the case inside.

Indexation Benefit for Acquisition Costs Based on Payment Year’s Index: ITAT

August 21, 2023 3381 Views 0 comment Print

Analysis of ITAT Delhi’s ruling in Bushra Javed Vs ACIT: Indexation benefits for acquisition costs based on payment year. Read the full legal insight here.

Supply of rolling stock not taxable in India as transfer of title took place outside India

August 18, 2023 552 Views 0 comment Print

ITAT Delhi held that the receipts from offshore supply of rolling stock (train sets) cannot be taxable in India as the transfer of title over the goods has taken place outside India.

TPO order passed after time limit prescribed u/s 92CA is barred by limitation

August 18, 2023 3567 Views 0 comment Print

ITAT Mumbai held that as per section 92CA of the Income Tax Act, TPO can pass the order at any time before 60 days prior to the date on which period of limitation referred u/s 153 expires. TPO order passed after the prescribed time limit is non-est and barred by limitation.

Adoption of lower FMV based on DVO report unjustified as specific feature of property not considered

August 17, 2023 1431 Views 1 comment Print

ITAT Delhi held that there is no justification of adopting lower Fair Market Value (FMV) merely on the basis of DVO report as DVO has failed to consider the specific features of the property commanding higher value.

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