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 : ITAT Delhi confirmed deletion of addition on alleged diversion of interest-bearing funds, holding that hypothetical or notional in...
Income Tax : The Tribunal held that commission paid to foreign agents for services rendered outside India is not taxable in India. Consequently...
Income Tax : The issue was whether commission payments were genuine business expenses. The Tribunal held that disallowance based on non-respons...
Income Tax : The Tribunal held that interest expenses cannot be disallowed when the trust merely facilitates transactions and costs are reimbur...
Income Tax : Consistency over technicalities: ITAT Mumbai allowed actuarial pension provision as an ascertained liability, rejected mechanical ...
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 held that while selecting the comparables transactions or entities, in case of international transactions, the basis should be one of similarity with the control transactions/entities and mere broad similarity is not sufficient.
ITAT Bangalore held that year-end expense provisions can attract TDS under the IT Act. The matter was restored for limited verification to determine liability under Sections 201(1) and 201(1A).
ITAT Ahmedabad allowed three appeals for statistical purposes by setting aside CIT(A) orders and directing fresh adjudication, subject to deposit of ₹5,000 per case in the PM National Relief Fund.
The Tribunal ruled that Section 40(a)(ia) cannot be used to penalize deduction under an incorrect TDS provision when tax was actually deducted. The expenditure disallowance was rightly deleted.
The AO added expenditure based solely on a mistaken audit report entry. The ITAT deleted the addition after confirming from the concerned party that no transaction occurred.
The Tribunal clarified that even where the assessee owns more than ten trucks, Section 44AE can be used as a fair yardstick for income estimation. Arbitrary assessment and multiple additions were set aside.
The Tribunal held that purchases from a foreign supplier were genuine as goods were imported through customs and duly recorded in books. It upheld deletion of addition under Section 68 on this ground.
The Tribunal ruled that failure to examine whether payees discharged tax liability vitiates proceedings under Section 201. The case was sent back to the AO to verify compliance and re-decide the issue.
The dispute involved denial of indexed interest while computing long-term capital gains. The Tribunal ruled that interest incurred wholly for acquiring an asset is deductible under Section 48.
The Tribunal held that disallowance of interest for non-deduction of TDS cannot be automatic when paid to an NBFC. The Assessing Officer must first verify whether the payee has offered the income to tax.
