#section 40(a)(ia)
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710 articlesIncome Tax

Income Tax
TPO adjustment towards technical know-how fees after accepting entity level margins is unsustainable
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Disallowance u/s 40(a)(ia) unsustainable as TDS already deducted and deposited
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Pigmy commission treatment as salary vis-à-vis TDS u/s 192 needs re-verification
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Reopening of proceedings u/s 147 sustainable as original return processed u/s 143(1)
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Depreciation allowed on payment of non-compete fee for business purpose
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Disallowance u/s. 14A cannot be more than exempt income
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TDS deductible on professional & technical services fees for developing of web enabled software
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Disallowance u/s 40(a)(ia) unsustainable as payment to non-resident not taxable in India
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Order passed without adequate reasoning is a non-speaking order
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Sales tax subsidy received by assesee from Haryana Govt. is capital receipt
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Invocation of section 263 justified if AO failed to enquire about non-deduction of TDS on CFS charges
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Proceedings u/s 263 unsustainable as enquiry already carried out by AO
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Amendment to section 40(a)(ia) vide Finance Act 2020 is retrospective in nature
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