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 ITAT Kolkata set aside the CIT(A)’s order concerning a large disallowance under Section 40(a)(ia) for non-deduction of TDS on advertising payments. The Tribunal remanded the matter, granting the agency a fresh opportunity to rely on CBDT Circulars that clarify the TDS obligations of intermediaries paying media houses.
ITAT Jabalpur deleted a lakh disallowance u/s 40(a)(ia) for non-TDS on interest, ruling the payee’s tax payment nullified the assessee’s technical default.
This ruling addresses a massive tax demand raised by CPC under Section 143(1) based solely on a clerical error in the original Form 3CD. The ITAT set aside the orders, holding that natural justice mandates the assessee be heard and the correct audit report considered before imposing such a significant liability.
The ITAT Pune dismissed the Revenue’s appeal, ruling against additions for ICDS adjustments, provision reversals (including liquidated damages and project costs), and Section 40(a)(ia) disallowance. The Tribunal held that subsequent reversal of provisions cannot be taxed again if the original provision was disallowed in earlier years, thereby preventing double taxation and upholding consistent accounting treatment.
Ahmedabad ITAT deletes ₹34 lakh disallowance on commission and job-work. TDS compliance proven via Form 26AS, and commission nexus established by increased sales.
ITAT quashes Rs..4.52 Cr disallowance; rules foreign agent commission and warehousing charges aren’t taxable FTS in India, thus no TDS under Section 195 required.
ITAT Kolkata partially allows appeal for Sukumar Solvent, slashing additions. Tribunal ruled only the 12% profit margin on excess stock is taxable and that TDS on freight is not required if PAN is provided by the transporter.
ITAT Mumbai ruled that referral payments made by an individual insurance agent to unlicensed persons do not fall under TDS provisions of Section 194D. Arbitrary disallowance of such commissions was deleted.
The ITAT Ahmedabad quashed a PCIT order, ruling that revisional power cannot be invoked for mere verification, and a specific error must be proven to show prejudice to revenue.
Tribunal held that EDC paid to HUDA is a statutory levy and not interest, quashing disallowance u/s 40(a)(ia) based on erroneous application of Section 194A.
