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 confirmed Section 263 revision after finding that the AO wrongly allowed delayed PF/ESI contributions despite binding Supreme Court law. The reassessment was deemed erroneous and prejudicial to Revenue.
The decision highlights that additions under Section 153C cannot stand when based only on third-party statements without seized material linking the assessee. The ruling stresses the need for concrete evidence before treating purchases as non-genuine.
ITAT Delhi restored the appeal to CIT(A) after the assessee challenged notice issuance beyond limitation and under wrong section. Key takeaway: adherence to correct procedure is crucial in income tax assessments.
ITAT Delhi remitted a case where CIT(A) upheld additions without examining available evidence. The ruling reinforces that authorities must fully consider documents and explanations before confirming unexplained investments.
Tribunal held that tax authorities erred in invoking Article 24A to deny capital gains exemption under Article 13(4A) without first satisfying preconditions of economic substance. The decision underscores that anti-abuse provisions cannot override bona fide investments made before 2017.
Since Netflix India functioned solely as a limited-risk distributor of access, not as a licensee of content or technology, therfore, TNMM benchmarking was accepted, and the royalty-based TP adjustment of ₹444.93 crores was unsustainable.
The Tribunal rejected the Revenue’s appeal against deletion of a ₹63.84 lakh addition under Section 68, observing that the assessee had already declared the same transactions as sales in audited accounts. Citing CIT v. Vishal Exports Overseas Ltd., it held that taxing such income again would lead to double taxation. The order reinforces that genuine recorded transactions cannot be recharacterized as unexplained cash credits.
The ITAT Mumbai ruled that payments received by a Singapore company from its Indian affiliate for Regional Service Agreement (RSA) support are not taxable as royalty under Section 9(1)(vi) or the DTAA. The Tribunal held that applying expertise for managerial and administrative services on a cost-sharing basis is a service, not the transfer of know-how.
The ITAT deleted transfer pricing adjustments for Advertisement, Marketing, and Sales Promotion (AMP) expenses, confirming no international transaction existed with the AE. The ruling held that the Bright Line Test (BLT) is invalid and that since the entity-level TNMM was accepted, no separate AMP adjustment was permissible.
Understand how interest under the Income Tax Act is calculated, including Sections 234A–234D, 244A, and Rule 119A mechanics for taxpayers.
