Income Tax : Karnataka High Court allows PCIT's appeal, upholding a Section 263 revision for non-disallowance of commission payments without TD...
Income Tax : Understand the penalties, interest, and disallowance of expenditure under Section 201 for failure to comply with TDS provisions in...
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 : Learn about disallowances under Income Tax Act sections and their reporting requirements in Form 3CD during tax audits. Key provis...
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 : Section 40(a)(ia) is amended via Finance (No. 2) Act, 2014 to restrict the amount of disallowance for non-deduction of tax to 30% ...
Income Tax : The existing provisions of section 40(a)(ia) of Income-tax Act provide for the disallowance of expenditure like interest, commissi...
Income Tax : The Delhi High Court held that the issues raised by the Revenue were either covered by binding precedents or based on factual find...
Income Tax : The Tribunal restricted the Section 14A disallowance to exempt income and deleted additions relating to bad debts, tea and coffee ...
Income Tax : The ITAT Chandigarh held that no TDS was deductible where professional fees paid to each payee were below the statutory threshold....
Income Tax : Bangalore ITAT held that mine development expenditure incurred by a mining contractor was allowable as a revenue deduction under S...
Income Tax : The ITAT Delhi held that an adjustment against excess contributions already made to an approved gratuity fund could not be disallo...
Income Tax : Circular No. 3/2015 Section 40(a)(i) of the Act stipulates that in computing the income chargeable under the head "Profits or gain...
Income Tax : Sub: Deduction of tax at source under Section 195 read with Sections 201 of the Income-tax Act, 1961 relating to payment made to a...
Income Tax : Circular No. 10/DV/2013-Income Tax It has been brought to the notice of the Board that there are conflicting interpretations by j...
ITAT Delhi upholds capital receipt status of E-tax subsidies and deletes disallowances on leasehold expenses, Section 14A, bank charges, and MAT additions for PVR Ltd.
ITAT Mumbai held that TDS need not be deducted on year-end expense provisions where payees are unidentifiable and liability crystallizes later. Case remanded for factual verification.
Karnataka High Court held that notice under section 148 of the Income Tax Act issued and served without signature of the Assessing Officer is a foundational defect and the same cannot be ignored. Accordingly, assessment order passed thereon is invalid.
ITAT Delhi held that trade scheme payment to sales promoters whether pure reimbursement or not needs proper verification and since AO granted relief without proper verification and application of mind, PCIT rightly invoked revisionary proceedings u/s. 263.
ITAT Ahmedabad confirmed the disallowance of Rs.1.21 crore in subcontract expenses because the taxpayer failed to provide sufficient corroborative evidence to substantiate the payments, especially those linked to a director’s relative. The Tribunal upheld the AO’s finding that the genuineness of the expenditure was not satisfactorily proved.
The Tribunal upheld that a provision made for arrears of VDA, PFD, and HRA pursuant to a High Court directive represented a crystallized liability. Since the assessee’s obligation was judicially enforceable, the expenditure was allowable. Disallowance was correctly limited to 30% under Section 40(a)(ia) for TDS non-compliance.
ITAT Mumbai allowed a Rs.109.73 Cr relief, ruling that payments for centralized support services like HR and IT are not taxable as FTS or Royalty under India-Belgium DTAA. court held that these routine corporate activities lacked element of transferring technical knowledge or expertise.
The ITAT Kolkata set aside the CIT(A)’s order concerning a large disallowance under Section 40(a)(ia) for non-deduction of TDS on advertising payments. The Tribunal remanded the matter, granting the agency a fresh opportunity to rely on CBDT Circulars that clarify the TDS obligations of intermediaries paying media houses.
ITAT Jabalpur deleted a lakh disallowance u/s 40(a)(ia) for non-TDS on interest, ruling the payee’s tax payment nullified the assessee’s technical default.
This ruling addresses a massive tax demand raised by CPC under Section 143(1) based solely on a clerical error in the original Form 3CD. The ITAT set aside the orders, holding that natural justice mandates the assessee be heard and the correct audit report considered before imposing such a significant liability.
