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Limitation Period under Section 144C vis-à-vis Section 153 of the Income-tax Act: Supreme Court Clarifies DRP Timelines, Assistant Commissioner of Income Tax (International Taxation) & Others Versus Shelf Drilling Ron Tappmeyer Ltd. Etc.
The issue before the Supreme Court
concerned the correct interpretation of the limitation provisions under Section
153 of the Income-tax Act, 1961, in cases where the special assessment
procedure under Section 144C, i...
TDS Credit Cannot Be Denied Due to System Mismatch in Form 26AS – Relief to Deductee | Sumit Devendra Rajani v. ACIT (Gujarat HC)
In many cases, assessees are confronted with tax demands solely on the ground that the credit of Tax Deducted at Source (TDS) claimed by them is not fully or correctly reflected in Form 26AS, despite the fact that tax ha...
No Transfer Pricing Adjustment on Interest for Delayed AE Receivables Where Working Capital Adjustment Granted: ITAT Delhi in ERM India Pvt. Ltd. v. DCIT
In
ERM India Private Limited, Gurugram v. Assessment Unit (DCIT, Circle 7(1),
Delhi), the Delhi Bench of the Income Tax Appellate Tribunal examined the
validity of a transfer pricing adjustment made on account of alle...
Offshore Supply Not Taxable in India and No Supervisory or Fixed Place PE Established: ITAT Delhi in SAIC Motor Corporation Ltd. v. ACIT
In
SAIC Motor Corporation Ltd., China v. Assistant Commissioner of Income Tax
(International Taxation), Gurgaon, the Delhi Bench of the Income Tax
Appellate Tribunal examined whether profits from offshore supply of KD...
Donation of Sale Proceeds to Another Charitable Trust Held Valid Application of Income: ITAT Delhi in ITO (E) v. Prakash Sewa Trust
In
Income Tax Officer (Exemption), Ward-2(4), New Delhi v. Prakash Sewa Trust,
the Delhi Bench of the Income Tax Appellate Tribunal examined whether exemption
under Sections 11 and 12 of the Income-tax Act, 1961 could...
Segment-Wise Transfer Pricing Mandatory and Non-Compete Fee Treated as Revenue: ITAT Delhi in Spectris Technologies Pvt. Ltd. v. ITO
In
Spectris Technologies Pvt. Ltd., Gurgaon v. Income Tax Officer, New Delhi,
the Delhi Bench of the Income Tax Appellate Tribunal examined two recurring
issues for Assessment Year 2009–10—first, the correctness o...
Depreciation on Goodwill from Amalgamation Allowed – ITAT Mumbai Follows Smifs Securities in ACIT vs Siyaram Silk Mills Ltd
The appeal filed by the Revenue was directed
against the order passed by the Commissioner of Income Tax (Appeals) for
Assessment Year 2017-18, arising from an assessment framed under section 143(3)
of the Income-tax A...
Section 68 Addition Deleted for Opening Balances and Genuine Loans – ITAT Mumbai in ACIT vs Supreme Lake View Bungalows Pvt. Ltd.
The appeal filed by the Revenue was directed
against the order of the Commissioner of Income Tax (Appeals) for Assessment
Year 2022-23, arising from an assessment framed under section 143(3) read with
section 144B of ...
Ex-Parte Assessment and Appeal Set Aside with Costs; Matter Remanded for Fresh Adjudication: ITAT Mumbai in Sunni Hanfi Mashayaki Momin Trust v. ITO
The appeals filed by Sunni Hanfi Mashayaki Momin
Trust pertained to Assessment Years 2014-15 and 2017-18 and were directed
against the orders passed by the National Faceless Appeal Centre under section
250 of the Inco...
ITAT Mumbai Allows Withdrawal of Appeal Under Direct Tax Vivad Se Vishwas Scheme, 2024 – Solenis Chemicals India Pvt. Ltd. vs ACIT
The appeal filed by Solenis Chemicals India
Private Limited before the Income Tax Appellate Tribunal, Mumbai Bench,
arose from an assessment order passed under section 143(3) read with sections
144C(13) and 144B of th...