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 held that on-money admitted by a seller before the Settlement Commission cannot be presumed against the purchaser without independent evidence. In absence of any seized material or proof of cash payment, the addition u/s 69 was deleted.
ITAT Delhi emphasized that FAR analysis governs segmentation for transfer pricing purposes. Artificial aggregation without disproving segmental allocation cannot justify adjustments.
The tribunal held that every oil well constitutes an independent undertaking eligible for deduction under section 80IB(9). The key takeaway is that profits of individual wells cannot be clubbed merely because they operate under a single contract.
The Tribunal ruled that inadvertent omission of claiming advance tax does not bar interest under Section 244A. Authorities cannot withdraw interest through Section 154 rectification for such mistakes.
ITAT Bangalore allowed deduction of ₹55.4 crore ESOP expenses under section 37, holding it as employee compensation cost. ESOP costs may be deductible even if cross-charged from parent company.
ITAT held that the assessee had proved identity, creditworthiness, and genuineness of the lender through affidavits, ITR and audited accounts. Since the AO brought no contrary evidence, the Section 69A addition was deleted.
Madras High Court held that payment made for International Private Leased Circuits [IPLC] doesn’t constitute royalty within the expression provided under clause (iva) to Explanation 2 to section 9(1)(vi) of the Income Tax Act. Hence, disallowance u/s. 40(a)(i) of the Income Tax Act not sustained.
The Tribunal ruled that interest could not be disallowed when ample interest-free funds existed and no link was shown between overdraft borrowings and partners’ drawings. The key takeaway is that presumption of utilisation of own funds applies when mixed funds are available.
The Tribunal ruled that offshore supply receipts could not be taxed as the Revenue failed to establish any Permanent Establishment. It confirms that FOB-based offshore execution shields non-residents from Indian taxation.
ITAT held that Section 69 cannot apply when the assessee is not proved to own the cash. Unrebutted affidavits established the source, and mere suspicion cannot justify an addition.
