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Income Tax : ITAT Hyderabad held that CPC cannot make adjustments under Section 143(1)(a) without issuing prior intimation to the assessee as m...
Income Tax : The Delhi ITAT held that belated filing of Form No. 67 is only a procedural lapse and cannot extinguish substantive Foreign Tax Cr...
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Income Tax : Notification No. 3/2011 - Income Tax WHEREAS the annexed Agreement among the Governments of SAARC (South Asian Association for Re...
Income Tax : Notification No. 86/2010-Income Tax Whereas, an Agreement and the Protocol between the Government of Republic of India and the Gov...
Income Tax : Notification No. 36/2010-Income Tax Whereas, an Agreement and the Protocol between the Government of Republic of India and the Gov...
Income Tax : Notification No. 25/2010-Income Tax In exercise of the powers conferred by Explanation 2 to section 90 of the Income-tax Act, 1961...
ITAT Jaipur held that disallowance of exemption under section 11 of the Income Tax Act on the basis of bonafide error in ITR is not justified. Accordingly, appeal allowed and benefit granted.
The company had sought a NIL tax deduction certificate under Section 195, arguing that the payments did not constitute royalty either under domestic tax law or the DTAA, and that Intelsat had no permanent establishment (PE) in India.
Patna High Court held that taxpayer will not be eligible for Direct Tax Vivad Se Vishwas Scheme 2024 [DTVSV Scheme] against notice issued under section 148 of the Income Tax Act since dispute tax is not ascertainable.
It also referred to similar findings in Matrix Partners India Investment Holdings, LLC vs DCIT and other precedents, reinforcing that exempt income did not form part of the computation of total income under Indian law.
Delhi High Court held that Nokia Network OY does not have Fixed Place Permanent Establishment in India [PE] and hence offshore supplies were not taxable in India. Appeal stands dismissed, accordingly.
ITAT Pune rules on Foreign Tax Credit (FTC) in JCIT (OSD) Vs Raj Surendra Mohan Hajela, addressing the delay in Form 67 submission and its impact on tax claims.
Smt. Syeda Rahimunnisa and Syed Hyder Hussaini are wife and husband whereas the respondent no. 1(a) to 1(f) are the legal heirs of one late Haji Mian being mother, wife, sons and daughters respectively.
ITAT Delhi held that advertisement and distribution revenue earned by Discovery Asia Inc. is taxable as per Mutual Agreement Resolution (MAP) as decided by competent authority of India & USA. Accordingly, appeal allowed partially.
Punjab and Haryana High Court held that the same assessing officer is required to pass an order under the new scheme after giving notice under Section 148 of the old Act. Thus, all the writ petition are dismissed.
In the instant case, assessee had not filed any return within stipulated time framed u/s 139(1), but had filed the return u/s 139(8A) (updated return) on 31.03.2023 along with Form 67 filed online on the said date claiming FTC.
