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...
The Court held that interest paid for delayed Agricultural Income Tax cannot be deducted under Section 37. Since AIT itself is not deductible, the related interest also fails eligibility. The ruling confirms that such payments do not qualify as business expenditure.
ITAT Delhi held that DRP is a quasi-judicial authority and is required to issue directions on all the objections raised by assessee. Failure to adjudicate certain components results into violation of principles of natural justice. Accordingly, matter set aside to file of DRP.
ITAT Surat relied on precedents (Hari Gopal, Marksans Pharma, Boparai P. Ltd.) to hold that ad-hoc or percentage-based additions do not trigger Section 271(1)(c) penalty. Appeal allowed, penalty deleted.
The ITAT ruled that payments for typing and DTP services fall under Section 194C, not 194J, and correctly attract 2% TDS. As a result, the addition made under Section 40(a)(ia) was deleted.
Tribunal confirmed that powers to question “source of source” under section 68 exist only from 01-04-2023. Additions on unsecured loans and student deposits were deleted, while TDS disallowance was remanded.
Since the assessee did not receive notices sent to a wrong email, non-compliance findings were unsustainable. The ITAT directed the Assessing Officer to examine evidence and pass a speaking order after granting a proper hearing
The Tribunal upheld the CIT(A)’s findings after noting the assessee produced no evidence to counter verified disallowances. Key takeaway: appellate relief requires substantiated rebuttal of factual verification.
The tribunal held that the State Electricity Board consumer tariff of ₹6.62/unit was the valid internal CUP for captive power transfer. Rejecting comparisons with generating companies, it ruled that no downward adjustment was required. The key takeaway is that actual SEB purchase rates can reliably determine market value for 80IA claims.
Tribunal held that interest disallowance for non-deduction of TDS must be restricted to 30% under amended provisions. It also remanded issue of estimated interest on interest-free advances for verification.
ITAT Delhi ruled that cash deposits recorded in audited books cannot be treated as unexplained income under Section 68. Additions made by the AO and CIT(A) during demonetization were deleted, preventing double taxation.
