Income Tax : This guide explains when penalties can be imposed under various provisions of the Income-tax Act, 1961. It also outlines the appli...
Income Tax : ITAT Mumbai held that penalty under Section 270A cannot be levied merely because income was estimated after rejection of books. Si...
Income Tax : The article explains how transactions between associated domestic entities exceeding ₹20 crore must comply with arm's length pri...
Income Tax : The Tribunal ruled that non-specification of the precise statutory charge under sections 270A(2) and 270A(9) violated principles o...
Income Tax : Budget 2026 proposes allowing taxpayers to file an updated return even after receiving a reassessment notice under Section 148. Wh...
Income Tax : Explore amendments to section 253 of Income-tax Act, adjusting time limits for filing appeals to the Income Tax Appellate Tribunal...
Income Tax : ITAT Delhi held that IT, salary and travel reimbursements without any profit element were not taxable and deleted the disallowance...
Income Tax : ITAT held that an Assessing Officer cannot substitute the DCF method chosen under Rule 11UA with the NAV method without legal just...
Income Tax : ITAT held ₹33 crore settled rights over the entire land, allowing full indexed acquisition cost and rejecting proportionate rest...
Income Tax : ITAT excluded EDCIL, Just Dial, Info Edge and India Exposition Mart as transfer pricing comparables due to functional differences ...
Income Tax : The Tribunal ruled that a penalty notice lacking a specific allegation of under-reporting, misreporting, or the applicable clause ...
ITAT Bangalore deleted the penalty under Section 270A after holding that the assessee’s incorrect claim arose from a bona fide misunderstanding of a newly introduced provision under Section 71(3A).
The ITAT held that penalty proceedings under Section 270A were invalid because the Assessing Officer did not specify the applicable statutory charge under the provision. It ruled that such omission violated the principles of natural justice and quashed the penalty.
The ITAT held that CSR expenditure disallowed under Section 37(1) does not automatically bar deduction under Section 80G where statutory conditions are fulfilled. It allowed the deduction for donations made to an eligible Section 80G-registered trust.
The ITAT held that foreign exchange gains arising from realization of export proceeds from services rendered to associated enterprises are operating in nature for transfer pricing purposes. It directed verification by the Assessing Officer and corresponding computation of the arm’s length margin.
The ITAT found inconsistencies in the selection and rejection of comparable companies for determining the arm’s length price of international transactions. It directed inclusion and exclusion of specific comparables and partly allowed the assessee’s appeal.
The Mumbai ITAT held that reassessment proceedings under Section 147/148 were invalid where the case was based on search material requiring action under Section 153C. The ruling reinforces that search-related assessments for third parties must follow the special procedure under Section 153C, not regular reassessment provisions.
The ITAT ruled that deduction of TDS does not excuse failure to file an income tax return. The decision emphasizes that income discovered through departmental records can attract penalty for under-reporting under Section 270A.
The Bangalore ITAT held that ambiguity in the penalty proceedings rendered the levy unsustainable. The Tribunal emphasized strict compliance with the statutory framework under Section 270A.
The article explains how transactions between associated domestic entities exceeding ₹20 crore must comply with arm’s length pricing rules. Failure to do so may result in recomputation of income and penalties for under-reporting or misreporting under Section 270A.
The Delhi ITAT held that receipts from sale and restricted use of standard cybersecurity software could not be taxed as Fees for Technical Services. The Tribunal relied on judicial precedents dealing with standardised technology offerings.
