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Income Tax : The Income Tax Department explains how faceless assessments under Section 144B operate through the e-Filing portal without requiri...
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The Tribunal held that delay in filing Form 67 is a procedural lapse. It restored the matter to the AO to verify and allow Foreign Tax Credit if eligible.
ITAT held that interest under Section 220(2) must be recomputed based on reduced assessed income after rectification under Section 154. However, it clarified that interest will still run from the original demand date.
Tribunal directed allocation of common head-office expenses (and common income) to eligible industrial undertakings when computing deductions under sections 10B and 80-IB, following prior coordinate-bench rulings; AO must apply the earlier directions on remand. Key takeaway: common corporate overheads and income were to be apportioned to units for deduction-computation as previously directed.
The Tribunal held that when the difference between purchase price and DVO valuation falls within the 10% tolerance band, no addition can be made under section 56(2)(vii). The addition based on stamp duty value was therefore deleted.
ITAT held that delay in filing Form 9A cannot automatically result in denial of exemption under Section 11. The issue was sent back for reconsideration after examining the condonation application before the Commissioner.
The Tribunal ruled that an assessment order passed after DRP directions is still subject to revision under Section 263. It held that there is no statutory bar preventing the Principal Commissioner from revising such orders.
The case involved CPC adjustment denying deduction for employees’ PF contribution deposited after statutory due dates. The tribunal ruled that before the Supreme Court’s later decision, the issue was debatable and could not be adjusted under Section 143(1).
ITAT Delhi held that Oracle India Private Limited is an independent legal entity and existence of Oracle India Private Limited cannot be considered as permanent establishment of Oracle Systems Corporation. Hence, there is not question of attribution of profit to Permanent Establishment.
ITAT Panaji held that disallowance of audit fees is not justifiable since commencement of business operation is recognised under the Companies Act and expenditure was incurred wholly and exclusively for business. Accordingly, appeal allowed to that extent.
ITAT ruled that once the Assessing Officer makes no addition on the issue forming the basis of reopening, other additions cannot survive. MAT demand under Section 115JB was therefore struck down as unlawful.
