Income Tax : An overview of Section 144 of the Indian Income Tax Act, which allows an Assessing Officer to make a best judgment assessment in c...
Income Tax : An analysis of Sections 263 and 264 of the Income-tax Act, 1961. It details the conditions, scope, and judicial precedents for the...
Income Tax : Gujarat HC quashed a Section 264 revision order and remanded the matter after finding the petitioner's contentions were cursorily ...
Income Tax : ITAT held penalty under Section 271AAC(1) is unsustainable after deletion of Section 69A addition under Section 264 and set aside ...
Income Tax : Bengaluru ITAT quashed Section 271D penalties as time-barred, holding the six-month limitation under Section 275(1)(c) expired bef...
Income Tax : ITAT held that delayed filing of Form 67 is a procedural lapse and directed the AO to grant foreign tax credit claimed under Secti...
Income Tax : The ITAT held that an assessee can contest a Section 143(1) adjustment in an appeal against the assessment order if the adjustment...
The Supreme Court refused to interfere with the High Court’s decision dismissing a revision filed after nearly seven years. It affirmed that unexplained and excessive delay defeats relief under Section 264.
The High Court upheld rejection of a belated revision filed nearly seven years after rectification denial. It ruled that no sufficient cause was shown to condone the inordinate delay.
The court examined whether withholding tax could be imposed solely on the basis of an alleged virtual service permanent establishment. It ruled that such a concept is not recognised under the DTAA and remanded the matter for fresh consideration.
The Court held that self-assessment tax paid due to failure of an initial IDS declaration must be treated as payment under the revived Scheme, preventing double taxation of the same income.
The High Court ruled that tax authorities cannot ignore a binding ITAT Special Bench decision under Section 264 merely because the department has appealed it. Judicial discipline requires adherence unless the ruling is stayed or overturned.
The issue was whether reassessment could be initiated beyond four years after a completed scrutiny assessment. The Tribunal held that reopening was barred as there was no failure to disclose material facts.
The issue was whether exemption under Section 11 could be denied solely due to wrong data punching. The court ruled that inadvertent human errors cannot defeat a lawful exemption
The Delhi High Court held that sponsorship payments included consideration for worldwide use of event trademarks. The ruling confirms that such rights constitute royalty liable to withholding tax.
Uttarakhand High Court held that order of the Competent Authority granting sanction or approval or refusing to grant sanction or approval u/s 151 of the Income Tax Act of 1961 is neither a revisable order, nor an appealable order.
The Tribunal held that penalties under Section 271D were invalid as they were imposed beyond the limitation period prescribed under Section 275(1)(c).
