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 case examined penalty levied on estimated additions and statutory disallowance. The Tribunal held that neither category amounts to concealment or inaccurate particulars.
ITAT ruled that the AO’s omission to apply TDS provisions on freight charges warrants revision. Proper application of statutory disallowances is mandatory in reassessment proceedings.
The Tribunal examined the validity of reopening and multiple expense disallowances. While relief was granted on cash payments and reimbursed interest, statutory interest on taxes was held to be non-deductible.
The Tribunal held that cash advances/on-money received for an ongoing real estate project cannot be taxed before completion when the Project Completion Method is consistently followed. Income already offered and accepted in the completion year cannot be taxed again earlier.
ITAT Mumbai held that where segmental accounts are not available, then proportionate adjustments have to be made only in respect of the international transactions with associated enterprises [AE]. Thus, TPO directed to compute the transfer pricing [TP] adjustment, restricting it to the international transactions undertaken with associated enterprises.
The issue was whether a deductor can be treated as in default for non-deposit of TDS when the payee has already paid tax on the income. ITAT held that no demand under Section 201(1) survives once the payee’s tax payment is established.
The issue was whether unsecured loans from directors routed through a partnership firm could be treated as unexplained cash credits. The Tribunal held that once identity, creditworthiness, and genuineness are proved through books and bank records, section 68 addition cannot survive.
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
