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 : 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 Delhi ITAT held that belated filing of Form No. 67 is only a procedural lapse and cannot extinguish substantive Foreign Tax Cr...
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 Ahmedabad held that addition on account of section 14A of the Income Tax Act while computing books profit under section 115JB of the Income Tax Act is not justifiable. Accordingly, addition u/s. 14A deleted and appeal of assessee allowed.
ITAT Delhi emphasized that Revenue must present convincing evidence of fraud or economic substance absence to deny DTAA benefits, following Delhi HC guidance in Tiger Global International.
The Bombay High Court quashed the AAR’s ruling that denied Mauritius DTAA benefits to Bid Services Division (Mauritius) Limited. The Court held that the petitioner was entitled to treaty protection on capital gains from the sale of MIAL shares. It ruled that legitimate corporate structures cannot be disregarded merely for resulting in tax advantages.
ejecting the Revenue’s approach, the Tribunal held that mere quantum of advertisement or marketing expenses cannot trigger transfer pricing adjustment without demonstrating a direct nexus with a foreign AE.
Tribunal held that where Form 67 is submitted before the completion of assessment, foreign tax credit must be allowed even if the filing was delayed. It observed that neither the Act nor Rule 128(9) imposes disallowance for delay.
The AIS is a comprehensive statement providing all tax and financial transaction details, including TDS, SFT, and external data, to the taxpayer. TIS is a summary of this information. Access via e-filing portal; feedback is possible.
The core issue was the denial of Foreign Tax Credit (FTC) due to two contradictory CIT(A) orders, one of which cited the late filing of Form 67. The ITAT ruled that since Form 67 was filed before the end of the Assessment Year as per the amended Rule 128(9), the assessee is entitled to the FTC. This decision confirms the extended time limit for filing Form 67 and upholds the principle that one appellate authority cannot overrule a final order of another appellate authority for the same year.
The ITAT ruled that receipts from the sale of power generated during the pre-commencement trial run of a plant are capital receipts, not taxable revenue income. This is because, under the matching principle, corresponding pre-operative expenses were capitalized to the fixed asset cost, justifying the deletion of the Rs. 42.56 crore tax addition.
The Tribunal held that the DTAA overrides the Income Tax Act, and income taxed abroad cannot be taxed again in India. The ITAT rejected the view that authorities lack power to condone delay, allowing the FTC claim after verification of the eventually filed Form 67.
ITAT ruled in Grasim Industries that a court-sanctioned scheme transfer before the 2021 amendment is a transfer by law, not a slump sale under Section 50B. The change is not retrospective.
