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...
While an error in computation was acknowledged, prejudice to Revenue was not established. The Tribunal quashed the revision for lack of both ingredients. The ruling clarifies strict thresholds for invoking section 263.
The dispute centered on whether co-insurance administration fees required tax deduction at source. The Tribunal upheld their allowability without TDS, noting the issue was repeatedly settled in earlier years. The key takeaway is that consistent past rulings in identical facts will be followed.
High Court quashed the adjustment made in the intimation under Section 143(1) disallowing deduction under Section 10B and declared the rectification order to be null and void as allowability of deduction under Section 10B was examined during regular assessment proceedings and accepted
The issue was whether further disallowance could be made after a suo motu 30% disallowance under section 40(a)(ia). The Tribunal ruled that any additional adjustment amounts to double disallowance and is impermissible.
The Tribunal held that revision under section 263 cannot introduce issues outside the original limited scrutiny mandate. The key takeaway is that the PCIT cannot widen the inquiry beyond CASS-selected parameters.
The ruling found that the authorities failed to examine party-wise payment limits before disallowing expenses for alleged TDS default. Key takeaway: threshold verification is essential before invoking section 40(a)(ia).
The case clarifies that commission paid to foreign agents for export facilitation abroad cannot be disallowed for non-deduction of tax. Absence of income accrual in India was decisive.
The Tribunal held that interest earned by a credit co-operative society from deposits with co-operative banks is deductible under section 80P(2)(d). The ruling follows settled law that such societies are distinct from co-operative banks.
ITAT Jaipur confirmed that Section 270A(6)(b) exclusion is inapplicable when accounts are incorrect or incomplete. Key takeaway: defective records make estimated disallowances liable to penalty.
ITAT held that Section 50C proviso is retrospective, allowing stamp duty value as on the agreement date where consideration was fixed earlier, significantly reducing LTCG exposure.
