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 : Denial of the 15% rate through summary processing was held invalid. Eligibility under section 115BAB requires examination and hear...
Income Tax : Professional and technical advisory services rendered from India to foreign clients in connection with overseas securities offerin...
Income Tax : In Purnasons Pvt. Ltd vs. ITO, ITAT Kolkata rules on the allowance of deductions under Section 80M of the Income Tax Act when divi...
Income Tax : Read the detailed analysis of Kolkata ITAT's ruling allowing deduction under Section 80M of the Income Tax Act for dividends distr...
Income Tax : Delhi High Court held that disallowance under section 80M of the Income Tax Act to the extent of divided distributed to the shareh...
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).
In present facts of the case, the Hon’ble Tribunal held that expenses made pertaining to Club Membership fees shall be allowed as business expenditure.
ITAT Delhi held that reopening of assessment under section 147 of the Income Tax Act unjustified in absence of failure on the part of the assessee to disclose fully and truly all the material facts.
The law is now well settled that for the purpose of deduction u/s.80M of the Act, only actual expenditure incurred has to be taken into consideration and there cannot be any estimate of expenditure that could be made thereon.
We know that before Finance Act, 2020 a dividend received from a domestic company is exempt in the hands of shareholders. Because company declaring dividend is required to pay Dividend Distribution Tax (DDT) under provisions of Section 115O of the Income Tax Act,1961 before crediting amount of dividend into account of shareholders. Many business houses […]
