Income Tax : The article explains how Section 80M applies only to domestic dividends, leaving foreign subsidiary dividends fully taxable in Ind...
Income Tax : We know that before Finance Act, 2020 a dividend received from a domestic company is exempt in the hands of shareholders. Because ...
Income Tax : Salient Features on Deduction us 80M with other ancillary aspects of the Income Tax Act, 1961 Amidst high expectations the Finance...
Income Tax : A. Existing Provisions relating to dividend taxation: (i) Tax implication in the hands of company: Under the existing laws, even t...
Income Tax : 1) Deductions u/s 80M is a Deduction not an exemption. The very basic difference between exemption & deduction is that losses ...
Income Tax : Delhi HC held interest on borrowings for strategic shareholding may qualify under Section 36(1)(iii). Matter remanded to AO to ver...
Income Tax : The ITAT held that CSR expenditure disallowed under Section 37(1) does not automatically bar deduction under Section 80G where sta...
Income Tax : The Tribunal held that donations qualifying under Section 80G do not become ineligible merely because they are incurred as part of...
Income Tax : Eempt income, which were disallowed under Section 14A could not be automatically added back to compute the book profit for Minimum...
Income Tax : Denial of the 15% rate through summary processing was held invalid. Eligibility under section 115BAB requires examination and hear...
Delhi HC held interest on borrowings for strategic shareholding may qualify under Section 36(1)(iii). Matter remanded to AO to verify business purpose.
The ITAT held that CSR expenditure disallowed under Section 37(1) does not automatically bar deduction under Section 80G where statutory conditions are fulfilled. It allowed the deduction for donations made to an eligible Section 80G-registered trust.
The Tribunal held that donations qualifying under Section 80G do not become ineligible merely because they are incurred as part of CSR obligations. The deduction was allowed following earlier decisions in the assessee’s own case.
Eempt income, which were disallowed under Section 14A could not be automatically added back to compute the book profit for Minimum Alternate Tax (MAT) under Section 115JB without pinpointing real, actual expenditures recorded in the books of accounts by tax authorities that possess a direct nexus with the tax-free earnings.
The article explains how Section 80M applies only to domestic dividends, leaving foreign subsidiary dividends fully taxable in India. This creates economic double taxation for Indian parent companies.
Denial of the 15% rate through summary processing was held invalid. Eligibility under section 115BAB requires examination and hearing, not mechanical CPC adjustments.
Professional and technical advisory services rendered from India to foreign clients in connection with overseas securities offerings qualify for deduction under Section 80-O as there was coordinate Bench’s decision in the assessee’s own case for AY 1995-96
In Purnasons Pvt. Ltd vs. ITO, ITAT Kolkata rules on the allowance of deductions under Section 80M of the Income Tax Act when dividends are distributed within the due date.
Read the detailed analysis of Kolkata ITAT’s ruling allowing deduction under Section 80M of the Income Tax Act for dividends distributed by Purnasons Pvt Ltd vs ITO.
Delhi High Court held that disallowance under section 80M of the Income Tax Act to the extent of divided distributed to the shareholders unsustainable in law. Accordingly, disallowance rightly deleted by CIT(A).
