Income Tax : Summary of Section 40A disallowances, including payments to related parties, cash payments, gratuity provisions, non-statutory fun...
Income Tax : Understand nuances of claiming tax deductions on payments to relatives in business. Learn how Section 40A(2) of Income Tax Act, 19...
Income Tax : The issue under consideration in this write up is whether disallowance u/s 40(a)(ia), 40A & 43B of Income Tax Act, 1961 are at...
Income Tax : Introduction Section 40A(2) of Income Tax Act, 1961 deals with payments to relatives and associated persons. It provides that wher...
Income Tax : Mumbai ITAT ruled that transfer of professional fees between branches through journal entries did not attract TDS liability. The T...
Income Tax : ITAT Bangalore held that NIL taxable income disclosed by an Alternative Investment Fund does not automatically negate its creditwo...
Income Tax : The issue was whether commission payments were genuine business expenses. The Tribunal held that disallowance based on non-respons...
Income Tax : The ITAT held that the Assessing Officer wrongly compared dissimilar email marketing services to determine excess payment. The rul...
Income Tax : The Tribunal reversed additions made towards alleged suppressed rent and bogus salary expenses. It emphasized factual consistency,...
Income Tax : Notification No. 8/2020-Income-Tax- CBDT has notified Other electronic modes by inserting New Income TAx Rule 6ABBA. It also amend...
Mumbai ITAT ruled that transfer of professional fees between branches through journal entries did not attract TDS liability. The Tribunal accepted ICAI records confirming the existence of the Ahmedabad branch.
ITAT Bangalore held that NIL taxable income disclosed by an Alternative Investment Fund does not automatically negate its creditworthiness. The Tribunal recognized the statutory pass-through taxation mechanism applicable to AIF structures.
The issue was whether commission payments were genuine business expenses. The Tribunal held that disallowance based on non-response and suspicion was not justified. The key takeaway is that conjectures cannot replace evidence in tax assessments.
The ITAT held that the Assessing Officer wrongly compared dissimilar email marketing services to determine excess payment. The ruling clarifies that only comparable services can be used for arm’s length evaluation, leading to deletion of the addition.
The Tribunal reversed additions made towards alleged suppressed rent and bogus salary expenses. It emphasized factual consistency, business necessity, and absence of tax avoidance in granting relief to the assessee.
The issue was whether revision under section 263 could be invoked when the Assessing Officer had accepted a legally possible view. The Tribunal held that where two views exist and the AO adopts one, the order is neither erroneous nor prejudicial.
The tribunal held that where the Assessing Officer conducted exhaustive enquiries and applied his mind in a 153C assessment, revision under section 263 is invalid. A mere change of opinion cannot justify reopening a concluded assessment.
Restoring the Assessing Officer’s findings, the Tribunal ruled that excessive salary to related directors can be disallowed when it substitutes dividend distribution. Reasonableness must be judged against comparable market remuneration.
The Tribunal considered whether disallowance under section 14A was justified merely because exempt income was earned. It ruled that without corresponding investments in the assessee’s books, section 14A cannot be invoked.
The case examined whether reassessment after four years was valid when the issues were already examined in scrutiny. The Tribunal held the reopening invalid as a mere change of opinion and quashed the reassessment.
