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...
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 Bombay High Court held that a corporate guarantee cannot be equated with a bank guarantee and upheld a 0.5% guarantee commission rate. The Court rejected the Revenue’s challenge to the 3% rate adopted by the Transfer Pricing Officer.
The ITAT found that provisions for identified legal and professional expenses represented crystallized liabilities requiring TDS deduction. The key takeaway is that only genuine contingent liabilities may escape such obligations.
Inter/Intra Circle Remittance Balance represented only internal transfer and reconciliation entries relating to assets and stock in transit between different Circles of the Assessee company. Since no expenditure or deduction had been claimed and the balances did not represent any real income or loss, the addition of Rs.1527.40 crores made by the AO and confirmed by the CIT(A) was deleted.
The ITAT held that compensation paid to terminate a land sale agreement was a business expenditure incurred for commercial reasons. The amount could not be treated as part of closing stock and was allowable under Section 37.
ITAT Kolkata held that TDS under Section 194C was not required on materials purchased for installation work. The disallowance under Section 40(a)(ia) was reduced substantially after excluding the material component.
The Tribunal deleted the disallowance of advertisement and publicity expenses after finding that sponsorship of football teams, tournaments, and green movement initiatives was undertaken for business promotion. It held that such expenditure qualified as allowable business expenses.
ITAT found that the Assessing Officer incorrectly treated consignment transactions as the assessees turnover based solely on cess payments. The ruling emphasizes that commission agents should be taxed on commission income and not on consignors turnover.
The Bangalore ITAT held that an assessee need not prove that a debt has actually become irrecoverable to claim a bad debt deduction. The Tribunal ruled that a proper write-off in the books of account is enough to qualify for the deduction.
State Bank of India Vs ACIT (ITAT Mumbai) The Mumbai Bench of the Income Tax Appellate Tribunal decided cross-appeals filed by a public sector bank and the Revenue for Assessment Year 2010-11. The case involved a large number of recurring banking-taxation issues including pension provisions, depreciation on securities, bad debts, section 14A disallowance, taxation of […]