Income Tax : The Income Tax Department has clarified the purpose, contents, and access to the Annual Information Statement (AIS) and Taxpayer I...
Income Tax : A detailed overview of limitation periods prescribed under the Income-tax Act reveals how missing statutory deadlines can lead to ...
Company Law : Understand Sections 89 and 90 of the Companies Act, 2013, focusing on legal ownership declarations and significant beneficial owne...
CA, CS, CMA : Discover the complexities of tax compliance for freelancers and gig workers, from understanding income sources to navigating legal...
Income Tax : Understand the concept of Updated Return under the Income-tax Act, its necessity, tax implications, and filing process. Get insigh...
Income Tax : The Central Government have notified the “Hong Kong Special Administrative Region of the People’s Republic of China” as ‘s...
Income Tax : ITAT Delhi held that IT, salary and travel reimbursements without any profit element were not taxable and deleted the disallowance...
Income Tax : ITAT held that delayed filing of Form 67 is a procedural lapse and directed the AO to grant foreign tax credit claimed under Secti...
Income Tax : ITAT held that foreign tax credit cannot be denied solely because Form No. 67 was filed after the return, subject to verification ...
Income Tax : The ITAT held that foreign exchange gains arising from realization of export proceeds from services rendered to associated enterpr...
Income Tax : The ITAT found inconsistencies in the selection and rejection of comparable companies for determining the arm’s length price of ...
Income Tax : The Income-tax Act, 1961 (the Act) provides that the Central Board of Direct Taxes may prescribe rules specifying the procedure fo...
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...
The Tribunal held that Dividend Distribution Tax is effectively a tax on shareholder dividend income and is subject to DTAA benefits. Excess tax collected above the treaty rate was ordered to be refunded.
The Tribunal held that no disallowance under Section 14A is warranted when exempt dividend arises incidentally from shares held as stock-in-trade in banking business. Applying Supreme Court precedents, it deleted the entire sustained disallowance, reaffirming that such income does not trigger Section 14A.
The issue was whether late filing of Form 67 bars foreign tax credit under DTAA. ITAT held that FTC is a substantive right under section 90 and cannot be denied for a procedural delay.
Uttarakhand High Court held that order of the Competent Authority granting sanction or approval or refusing to grant sanction or approval u/s 151 of the Income Tax Act of 1961 is neither a revisable order, nor an appealable order.
Tribunal held that a company engaged in diversified IT consultancy and transformation services cannot be compared with a routine software development service provider
The ITAT held that late filing of Form 67 cannot defeat a valid FTC claim. The ruling clarifies that procedural delays do not override substantive treaty rights.
The dispute centered on whether DRP directions allow completion of assessment beyond statutory time limits. The Tribunal clarified that section 144C does not create an independent limitation period. Procedural timelines cannot defeat the mandatory bar under section 153.
ITAT Mumbai ruled that ancillary software support services did not constitute FTS under the India–Singapore DTAA, deleting a ₹482.77 crore addition due to failure of the make available test.
The tribunal held that assessments completed through the DRP mechanism remain subject to the outer time limit prescribed under section 153. The key takeaway is that section 144C does not extend or override statutory limitation periods.
The Tribunal held that a final assessment passed after the expiry of Section 153 is invalid, even if it follows DRP directions. The is that limitation under Section 153 remains mandatory and cannot be bypassed through the DRP route.
