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 ITAT Chennai upheld the quashing of a reassessment for AY 2017-18, ruling the u/s 148 notice invalid. As more than three years had elapsed, u/s 151(ii) required sanction from the Principal Chief Commissioner (Pr.CCIT), not the Principal Commissioner (Pr.CIT), confirming the jurisdictional defect.
Kolkata ITAT rules that delayed Form 67 filing isn’t fatal to FTC claim. FTC is a substantive right under Section 90; Rule 128’s timeline is directory, not mandatory.
The ITAT Delhi bench, in a batch of 75 appeals led by Kosi Aviation Leasing Ltd., held that lease rentals received by Irish aircraft lessors from Indian airlines constitute profits from the operation of aircraft (Article 8 of the India-Ireland DTAA), not interest income (Article 11).
The ITAT Delhi ruled that a UK company’s receipts from Indian airlines for in-flight content are not taxable as royalty or fees for technical services, as no copyright or technical know-how was transferred.
The ITAT Chennai ruled that an Indian employee’s salary for services rendered in the US is not taxable in India, upholding the India-US DTAA and clarifying that the place of service, not receipt, determines taxability.
Ramachandra Reddy Vs DCIT: The Karnataka High Court quashes reassessment notices issued by jurisdictional AOs, holding that after the March 29, 2022 notification, all such proceedings must be conducted via the mandatory faceless regime under Section 151A.
The Income Tax Appellate Tribunal (ITAT) in Bangalore ruled that an individual’s right to claim Foreign Tax Credit (FTC) is substantive, and a delay in filing Form 67, a procedural requirement, cannot extinguish this right.
While so, the 2nd respondent sent a communication to the petitioner dated 14.05.2020 stating that relief under Section 90 of the Act i.e. Foreign tax credit was not considered, for the reason that Form 67 was not submitted along with income tax return.
ITAT Visakhapatnam held that assessment order passed under section 144 of the Income Tax Act without issuance of notice under section 143(2) is not sustainable and liable to be quashed since failure to issue notice u/s. 143(2) cannot be cured u/s. 292BB.
ITAT Jaipur held that delayed filing of Form No. 67 cannot be reason for denial of Foreign Tax Credit since filing of Form 67 is procedural/ directory requirement. Accordingly, appeal allowed and order of CIT(A) set aside.
