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 : Court ruled that reassessment notices under Section 148 must be issued through the faceless mechanism under Section 151A and the 2...
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 : 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 Court ruled that the Tribunal failed to examine key contractual clauses and judicial precedents before denying a deduction claim. It held that such non-consideration amounted to a mistake apparent from the record.
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.
The PCIT held the AO’s assessment under section 143(3) as erroneous and prejudicial to Revenue, directing fresh verification of various deductions. The assessee argued all claims were correctly examined, questioning the jurisdiction of section 263.
The ruling explains strict compliance requirements for specified domestic transactions, including maintaining detailed documentation for eight years. It highlights that failure to maintain, report, or furnish accurate information attracts penalties of up to 2% of transaction value.
ITAT Pune held that late filing of audit report cannot disentitle trust from availing benefit of section 11 of the Income Tax Act. Accordingly, order of CIT(A) allowing claim of exemption u/s. 11 upheld and appeal of revenue dismissed.
ITAT Hyderabad held that Transfer Pricing Officer [TPO] doesn’t have jurisdiction to scrutinize the claim of deduction under section 80IA of the Income Tax Act. Accordingly, addition made by AO on account of TP adjustment is not sustainable.
This case clarifies that eligibility for the Section 80-IA deduction must be verified project-by-project, irrespective of a taxpayer’s status in a previous year. The Tribunal held that only projects previously approved by the Settlement Commission are eligible, requiring fresh scrutiny for all new or unverified contracts.
Hyderabad ITAT dismissed an appeal, holding that a construction company couldn’t use the Section 153A assessment process, triggered by a search, to claim a Section 80-IA deduction it had omitted in its original return. Following the Supreme Court’s Shelly Products ratio, the Tribunal affirmed that the assessed income cannot be less than the income originally returned when the assessment was complete.
ITAT ruled in Grasim Industries that a court-sanctioned scheme transfer before the 2021 amendment is a transfer by law, not a slump sale under Section 50B. The change is not retrospective.
ITAT allows S. 80-IA deduction, ruling that the Form 10CCB filing delay is a procedural lapse that can’t deny a substantive claim, maintaining the judicial view post-Finance Act 2020.
