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Income Tax : Relying on its earlier ruling in the assessee’s own case, the Tribunal held that gross profit should be estimated at 0.40% rathe...
Income Tax : The Tribunal ruled that the limitation period for appeal commenced only when the assessee first received the ITBA screenshot revea...
Income Tax : Assessee argued that conclusions drawn from a 2005 survey on liaison offices could not be applied mechanically to later branch of...
Income Tax : Delhi ITAT directed exclusion of a comparable company engaged in video conferencing solutions after noting that the DRP had alread...
Income Tax : The Mumbai ITAT held that expenditure on software licences, maintenance, database access and periodic upgrades is allowable as rev...
Relying on its earlier ruling in the assessee’s own case, the Tribunal held that gross profit should be estimated at 0.40% rather than 2% of turnover. The order emphasised consistency in estimation across assessment years.
The Tribunal ruled that the limitation period for appeal commenced only when the assessee first received the ITBA screenshot revealing the basis of the outstanding demand.
Assessee argued that conclusions drawn from a 2005 survey on liaison offices could not be applied mechanically to later branch office structure. ITAT directed fresh examination of branch office’s actual functions and activities.
Delhi ITAT directed exclusion of a comparable company engaged in video conferencing solutions after noting that the DRP had already found it functionally incomparable to the assessee’s software distribution business.
The Mumbai ITAT held that expenditure on software licences, maintenance, database access and periodic upgrades is allowable as revenue expenditure. The Tribunal ruled that mere use of software does not create a capital asset or enduring ownership right.
ITAT Hyderabad held that CPC cannot make adjustments under Section 143(1)(a) without issuing prior intimation to the assessee as mandated by law. The Tribunal quashed the tax adjustment denying concessional tax benefits because the mandatory opportunity of response was not provided.
ITAT Rajkot held that reassessment proceedings were invalid because the approving authority merely stated Yes, I am satisfied without independent application of mind. The Tribunal treated Section 151 approval as a mandatory procedural safeguard.
The Tribunal held that a company engaged in high-end KPO and business solutions could not be compared with a routine captive BPO service provider. It also ruled that a comparable cannot be rejected solely for following a different financial year if reliable quarterly data is available.
The Tribunal examined disallowance made for delayed employee contributions under Section 143(1). It held that debatable issues cannot be adjusted at the processing stage, resulting in relief to the assessee. The ruling clarifies procedural boundaries.
The issue was denial of deduction due to delayed filing of Form 56F. ITAT held that delay is a procedural lapse and directed allowance of deduction.
