Income Tax : The ruling explains strict compliance requirements for specified domestic transactions, including maintaining detailed documentati...
Income Tax : Explore recent Supreme Court rulings (2023) on income tax issues. Highlights of key cases, analysis, and implications....
Income Tax : Explore deductions under Sections 80IA to 80IE for A.Y 2021-2025. Understand provisions, eligibility, quantum, and conditions. Sim...
Income Tax : Explore the rules and challenges of Domestic Transfer Pricing (DTP) in India. Learn about legal definitions, threshold limits, app...
Income Tax : Tax planning while setting up of a business with reference to location (2021-2022 A.Y, A.Y 2022-2023 , A.Y 2023-2024 and A.Y 202...
Income Tax : Section 80-IA [4 (iii)] of the Income Tax Act, 1961 provides for a tax holiday for 10 out of 15 years in respect of profits of any...
Income Tax : The Central Board of Direct Taxes (CBDT) has amended the Industrial Park Scheme 2008 and Rule 18C of the Income Tax Rules, 1962 to...
Income Tax : The Government has decided that telecom companies offering 3G services will not be allowed to claim tax breaks under Section 80 IA...
Income Tax : The Ahmedabad ITAT held that goodwill arising from a High Court-approved amalgamation qualified as an intangible asset eligible fo...
Income Tax : Calcutta High Court held that failure to investigate allocation of common head office expenses to eligible units rendered assessme...
Income Tax : The ITAT Delhi ruled that reimbursement of software costs to foreign AEs on a cost-to-cost basis could not be treated as a profit-...
Income Tax : ITAT ruled that deduction under Section 80JJAA could not be claimed where the business was acquired through amalgamation. The Trib...
Income Tax : ITAT Mumbai held that prolonged non-payment of interest and repeated amendments to loan agreements justified benchmarking AE loans...
Income Tax : Section 80-IA(4)(iii) of the Income-tax Act, 1961 - Deductions - Profits and gains from Industrial Infrastructure Undertakings, et...
Income Tax : Notification No. 78/2010-Income Tax [F.No.178/100/2008-ITA-I], dated 11-10-2010 Government hereby notifies M/s. Marathon Nextgen ...
Income Tax : Notification No. 73/2010-Income Tax Whereas the Central Government in exercise of the powers conferred by clause (iii) of sub-sect...
Income Tax : Notification No. 66/2010-Income Tax in exercise of the powers conferred by clause (iii) of sub-section (4) of section 80-IA of the...
Income Tax : Notification No. 54/2010-Income Tax Whereas the Central Government in exercise of the powers conferred by clause (iii) of sub-sect...
The object of Section 80IA was to provide an impetus to the growth of infrastructure in the nation. A sound infrastructure is a sine qua non for economic development. Absence of infrastructure poses significant barriers to growth and development. A model which relied exclusively on the provision of basic infrastructure by the State was found to be deficient.
Gujarat High Court, when interest is paid on delayed payment, it can be treated as higher sale price which is converse situation to offering of cash discount because the transaction remains the same and there is no distinction $s to the source. Looking from’ this angle, the interest becomes part of the hire sale price and is clearly derived from the sales made and is not divorced therefrom
The Government has decided that telecom companies offering 3G services will not be allowed to claim tax breaks under Section 80 IA of the Income Tax Act. Benefits under Section 80 IA are extended to companies involved in infrastructure creation. In the telecom sector, existing operators are allowed to choose a block of 10 years (out of the first 15 years of operations) for availing themselves of the tax benefits.
Assessing Officer has not made out any case for disallowing even a part of deduction allowable under Section 80IA. Once any condition laid down under Sub Section 10 of Section 80IA are not satisfied that Sub Section cannot be invoked and therefore no disallowance of deduction under that section can be made.
In ACIT Vs Rogini Garments108 ITD 49 the Special Bench at Chennai held that relief allowed u/s 80-IA had to be deducted from profits and gains of assessee’s business on which relief u/s 80HHC of the Act is to be computed. Subsequently, the Madras High Court in SCM Creations 304 ITR 319 took a contrary view. The question whether Rogini Garments was impliedly overruled was referred
Contimeters Electrical Pvt. Ltd 317 ITR 249 (Del)- Tribunal had arrived at the correct conclusion that the requirement of filing of audit report along with the return was not mandatory but directory and that if the audit report was filed at any time before the framing of the assessment, the requirement of section 80IA(7) would be met.
