Income Tax : The Income Tax Department explains when interest is payable for delayed return filing, advance tax defaults, deferment of instalme...
Income Tax : Understand how interest under the Income Tax Act is calculated, including Sections 234A–234D, 244A, and Rule 119A mechanics for ...
Income Tax : Due to any reason, in case the income tax department makes an excess refund to the taxpayer. Such taxpayer will have to return the...
Income Tax : Section 234D in Income Tax Act, 1961 was introduced in the act to cover those situations where the refund was issued to the assess...
Income Tax : ITAT Delhi upheld deletion of the TP adjustment for a debt-free branch, partly allowed the Revenue's appeal on Section 234D, and d...
Income Tax : ITAT Rajkot quashed Section 147 reassessment as alleged escaped income of Rs. 34.30 lakh was below the Rs. 50 lakh threshold under...
Income Tax : ITAT held interest from head office and overseas branches is not taxable as payment to self, while interest from overseas banks al...
Income Tax : Transfer pricing principles dictate that a captive, risk-mitigated service provider could not be benchmarked against full-fledged,...
Income Tax : The ITAT Ahmedabad held that royalty payments should continue to be benchmarked under TNMM by following earlier decisions in the a...
ITAT Delhi upheld deletion of the TP adjustment for a debt-free branch, partly allowed the Revenue’s appeal on Section 234D, and dismissed cross objections.
ITAT Rajkot quashed Section 147 reassessment as alleged escaped income of Rs. 34.30 lakh was below the Rs. 50 lakh threshold under Section 149.
ITAT held interest from head office and overseas branches is not taxable as payment to self, while interest from overseas banks also fell outside Section 9(1)(v)(c).
Transfer pricing principles dictate that a captive, risk-mitigated service provider could not be benchmarked against full-fledged, risk-bearing entrepreneurs, companies owning substantial intellectual property, or those generating revenue through software products.
The ITAT Ahmedabad held that royalty payments should continue to be benchmarked under TNMM by following earlier decisions in the assessees own case. It found no reason to replace TNMM with CUP where identical facts had already been decided. The Department’s transfer pricing challenge was therefore dismissed.
Delhi High Court held the ITAT failed to properly examine the ‘make available’ test for secondment payments, set aside its order, and ruled for the Revenue.
The ITAT Mumbai held that transfer pricing adjustments for intra-group services were unsustainable because the TPO determined the arms length price without applying any prescribed method under Section 92C. It directed deletion of the adjustments on this technical ground.
The ITAT held that payments made to directors represented arranger fees and not prohibited sub-brokerage under SEBI Regulations. It deleted the entire disallowance under Section 37(1), finding no violation of law.
The ITAT Mumbai held that Section 69C cannot be invoked where expenditure is duly recorded in the books and its source is fully explained. It deleted the addition relating to royalty, commission, and technical service payments.
ITAT Delhi held that donations forming part of CSR expenditure are eligible for deduction under Section 80G if the statutory conditions are satisfied. The Tribunal ruled that disallowance under Section 37(1) does not bar a separate deduction under Chapter VI-A.
