Income Tax : The Income-tax Act mandates TDS on specified payments because tax collection is intended to occur at the source of income generati...
Income Tax : Taxpayers are advised to wait until departmental records are fully updated before filing AY 2026-27 returns. Filing too early may ...
Income Tax : The amendment explicitly includes manpower supply services under contractual provisions, making 1–2% TDS applicable instead of 1...
Income Tax : ITAT rulings clarify that deduction of tax under Section 194J does not automatically classify income as professional income under ...
Income Tax : Businesses are seeking a cap on dividend taxation for resident shareholders to address double taxation concerns. The proposal aim...
Income Tax : From October 2024, payments under Section 194J (professional fees) will be excluded from TDS under Section 194C (payments to contr...
Income Tax : Following is the summary of Suggestion /representation on behalf of the taxpayers/professionals in connection with the Direct tax ...
Income Tax : A representation is been made to CBDT Chairman by leading accounting and CA Organisations of India and it is been requested that...
Income Tax : It is suggested that the TDS limit for payment of professional or technical fees under section 194J may be increased from Rs. 3000...
Income Tax : On the issue of retrospective amendment, Union Finance Minister, Shri Pranab Mukherjee has said that he had given a commitment in ...
Income Tax : ITAT Delhi held legal services are not FTS under Section 9(1)(vii) and directed partner-wise DTAA examination. FTS addition was de...
Income Tax : Delhi High Court held the ITAT failed to properly examine the ‘make available’ test for secondment payments, set aside its ord...
Income Tax : The ITAT Chandigarh held that no TDS was deductible where professional fees paid to each payee were below the statutory threshold....
Income Tax : The ITAT Hyderabad held that payments made for Google AdWords constitute advertising contracts under Section 194C and not fees for...
Income Tax : The dispute concerned deduction of CSR expenditure incurred before Explanation 2 to section 37(1) became applicable. The ITAT held...
Income Tax : Law Relating to Tax Deduction at Source (TDS) on payments by broadcasters or television channels to production houses for product...
Income Tax : Circular No. F. No.275/73/2007-IT(B) Service Tax component to be considered for deducting tax on any sum paid as professional and...
The amendment explicitly includes manpower supply services under contractual provisions, making 1–2% TDS applicable instead of 10%. This resolves long-standing confusion and reduces compliance risks.
ITAT rulings clarify that deduction of tax under Section 194J does not automatically classify income as professional income under Section 44ADA.
Revenue argued that control and fixed hours created employment. The Tribunal ruled that such controls ensure discipline and contract enforcement, not employment. Result: TDS under Section 194J sustained.
The Tribunal held that discounts given to stockists in pharmaceutical distribution are part of sale transactions on a principal-to-principal basis. As no commission was paid, TDS under section 194H was held inapplicable.
Businesses are seeking a cap on dividend taxation for resident shareholders to address double taxation concerns. The proposal aims to align domestic taxation with global standards and improve investment sentiment.
The ruling clarifies that TDS must be deducted at the time of credit, even if amounts are booked as provisions. Merely claiming that no payment was made does not excuse non-deduction.
The issue was whether a deductor can be treated as in default for non-deposit of TDS when the payee has already paid tax on the income. ITAT held that no demand under Section 201(1) survives once the payee’s tax payment is established.
The ruling found that the authorities failed to examine party-wise payment limits before disallowing expenses for alleged TDS default. Key takeaway: threshold verification is essential before invoking section 40(a)(ia).
The Tribunal held that mere facilitation of third-party payments to an associated enterprise does not constitute a service. As no value addition was involved, applying a markup on reimbursements was found unsustainable.
ITAT Chandigarh held that initiation of revisionary proceeding under section 263 of the Income Tax Act for non-verification of notional interest cannot be justified since notional interest is not liable to be taxed in current year but is taxable only upon maturity hence there cannot be any evasion of tax.