Corporate Law : Supreme Court clarifies power to modify arbitral awards under Section 34 in Gayatri Balaswamy case, raising questions on finality,...
Income Tax : Learn about disallowed expenses under PGBP in India's Income Tax Act. Understand key sections like 37, 40, and 40A, and their impa...
Income Tax : Delhi HC rules reimbursements to NRAEs not subject to TDS as "fees for technical services," clarifying scope of Section 9(1)(vii) ...
Income Tax : Understand the impact of Section 43B(h) on businesses: Learn about deductions for MSME payments and the importance of timely payme...
Corporate Law : Discover the process and types of trademark assignment. Learn about procedures, required documents, and benefits for a smooth tran...
Corporate Law : Explore the proposed amendments to Regulations 35, 37, and 50 of the Competition Commission of India (General) Regulations 2009. L...
Income Tax : Allowability of Interest paid under Incometax Act, 1961: Presently, interest paid by the Government to an assessee is chargeable t...
Income Tax : The Mumbai ITAT held that reversal of securitisation provisions already disallowed in earlier years cannot be taxed again upon wri...
Income Tax : The Chennai ITAT held that deductions approved by DSIR under Section 35(2AB) cannot be disallowed merely on the basis of survey st...
Income Tax : The Supreme Court held that grants disbursed by a statutory corporation formed part of its core business functions and qualified a...
Income Tax : The Tribunal ruled that mere observations about cash transactions are insufficient to levy penalty under Section 271D. A specific ...
Income Tax : The ITAT Delhi ruled that reimbursement of software costs to foreign AEs on a cost-to-cost basis could not be treated as a profit-...
The Mumbai ITAT held that reversal of securitisation provisions already disallowed in earlier years cannot be taxed again upon write-back. The Tribunal ruled that such taxation would amount to double taxation.
The Chennai ITAT held that deductions approved by DSIR under Section 35(2AB) cannot be disallowed merely on the basis of survey statements or AO findings. The Tribunal ruled that the AO and DRP exceeded their jurisdiction by questioning deductions already certified in Form 3CL.
The Supreme Court held that grants disbursed by a statutory corporation formed part of its core business functions and qualified as deductible revenue expenditure. The ruling clarified that such grants were not mere application of income.
The Tribunal ruled that mere observations about cash transactions are insufficient to levy penalty under Section 271D. A specific finding establishing contravention of Section 269SS is mandatory before imposing penalty.
The ITAT Delhi ruled that reimbursement of software costs to foreign AEs on a cost-to-cost basis could not be treated as a profit-generating intra-group service. The Tribunal deleted the transfer pricing adjustment after finding the benchmarking method adopted by the TPO unjustified.
ITAT Chennai held that before the 2016 amendment, DSIR approval under Section 35(2AB) related to the in-house R&D facility and not yearly expenditure quantification. The Tribunal upheld full weighted deduction despite partial approval in Form 3CL.
The Mumbai ITAT held that donations made as part of CSR expenditure can still qualify for deduction under Section 80G if statutory conditions are satisfied. The Tribunal clarified that disallowance under Section 37 does not prohibit relief under Chapter VI-A.
The Delhi ITAT held that belated filing of Form No. 67 is only a procedural lapse and cannot extinguish substantive Foreign Tax Credit rights under sections 90/90A/91 and applicable DTAAs. The Tribunal directed verification and grant of FTC where the form was filed before completion of assessment proceedings.
The Chennai ITAT held that transfer pricing benchmarking cannot ignore extraordinary business circumstances arising from the shutdown of a major customer. The Tribunal upheld deletion of TP adjustment after accepting that sale of goods to the AE was a distress sale triggered by Nokia India’s closure.
The ITAT held that CSR expenditure disallowed as business expenditure under Section 37(1) can still qualify for deduction under Section 80G if statutory conditions are satisfied. Revision under Section 263 was accordingly quashed.
