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Income Tax : Explore recent Supreme Court rulings (2023) on income tax issues. Highlights of key cases, analysis, and implications....
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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 ...
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The Tribunal examined whether lease rent and allied charges from an IT Park were business income or property income. It held that systematic commercial operation with integrated services warrants business income treatment.
The Court held that the Revenues challenge failed since the issue had been conclusively decided by the High Court earlier. Deduction under Section 80IA(4) remained available where the assessee was found to be a developer of infrastructure facilities.
The Court held that findings of the appellate authorities clearly established the assessee’s role as a developer. With concurrent factual findings, the appeal was rejected for lack of any substantial legal question.
The ITAT ruled that customer discounts are deductible when quantified and finalised in the year of claim, even if labelled as prior-period items. The decision reinforces that timing of crystallisation outweighs book classification.
The Tribunal held that interest on income-tax refund is taxable in the year of receipt and qualifies for Section 80-IA deduction, regardless of the year to which the refund relates.
The Tribunal held that a deduction cannot be disallowed merely due to delayed filing of Form 10CCB when it was available before processing. Procedural delay does not defeat a valid deduction claim.
The High Court held that Fringe Benefit Tax and Section 14A disallowance cannot be added while computing MAT under Section 115JB. The ruling confirms that only adjustments expressly permitted by law can alter book profits.
The Tribunal held that deduction under section 80-IA cannot be allowed mechanically based on past relief. Each infrastructure project must be independently examined to determine whether it qualifies as development or is merely a works contract.
The Tribunal held that the tax department cannot substitute actual sale consideration with a notional market price without express legal provision, and deleted the entire addition.
The court held that deductions under Sections 80-IA and 80-HHC can be claimed simultaneously, subject only to an overall cap of 100% of business profits.
