Income Tax : Understand the statutory time limits for filings, applications, approvals, and settlement processes under the Income-tax Act, incl...
Income Tax : The AIS is a comprehensive statement providing all tax and financial transaction details, including TDS, SFT, and external data, t...
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 : Delhi ITAT held that Dividend Distribution Tax paid on dividends to non-resident shareholders could be restricted to the treaty ra...
Income Tax : The Tribunal ruled that delayed filing or incorrect disclosure in Form 67 does not automatically disentitle an assessee from claim...
Income Tax : The ITAT Kolkata held that delayed filing of Form No. 67 is only a procedural defect and cannot deprive an assessee of Foreign Tax...
Income Tax : The ITAT Kolkata held that delayed filing of Form No. 67 cannot deprive an assessee of Foreign Tax Credit under Section 90 and the...
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 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...
ITAT Hyderabad held that the final assessment under section 143(3) r.w.s 144C(13) passed beyond statutory time limits is invalid. The ruling reinforces that the outer limit under section 153 cannot be extended, emphasizing strict compliance with limitation provisions.
ITAT upheld deletion of ₹3.31 crore addition under Section 69, noting full disclosure of foreign assets and sufficient income. Revenue cannot levy additions where investments are legitimate and documented.
A genuine FTC claim of ₹1.03 crore was partly disallowed due to a technical placement error in Form 67. The Tribunal restored the claim and sent it to the AO for verification and proper allowance.
The Tribunal observed that Form 67 was available before 143(1) processing, making the denial of FTC unjustified. It set aside the appellate order and directed the AO to grant FTC after verification.
The Hyderabad tribunal clarified that section 144C provisions are procedural and cannot extend the statutory limitation under section 153. The AO passed the final assessment order after the permissible period, leading to quashing. The ruling strengthens the principle that statutory deadlines are paramount in tax proceedings.
The Tribunal held that deciding the appeal ex parte violated natural justice and remanded the FTC dispute for full reconsideration. appellate orders must not be passed without proper opportunity of hearing.
ITAT examined Revenue’s protective addition based on alleged beneficial ownership of foreign accounts. It upheld deletion after noting unresolved ownership and procedural gaps, emphasizing that protective additions require clear foundational evidence.
Understand the statutory time limits for filings, applications, approvals, and settlement processes under the Income-tax Act, including key compliance deadlines.
The Tribunal held that several comparables selected by the tax authorities failed the RPT filter and were functionally dissimilar, warranting exclusion. It ordered verification, directed inclusion of suitable event-management comparables, and remanded the interest-on-receivables and ICDS issues for fresh review.
ITAT Delhi held that the assessee is eligible for entire credit of foreign taxes, even if the taxability was nil consequent to the deduction on account of business losses or section 10A exemption. Accordingly, appeal is allowed.
