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Interesting and Noteworthy Decisions
Interesting and Noteworthy Decisions
ESOP allotment sale of shares application of section 49(2AB) subsequently claimed
Income Tax
TaxPub Creative Cell
Goodwill for entering into a JV whether taxable as capital gains
Income Tax
TaxPub Creative Cell
Allowability of club expenses
Income Tax
TaxPub Creative Cell
Income scope whether under section 44BB or 115A
Income Tax
TaxPub Creative Cell
Cost plus was a right method of benchmark in line
Income Tax
TaxPub Creative Cell
Satyam computers confession and reopening/reassessment of family member's assessments
Income Tax
TaxPub Creative Cell
Capital gains long term or short term--Right to property exists but possession not there--Duration of holding how reckoned.
Income Tax
TaxPub Creative Cell
Scope of section 44BB v. 44DA v. 115A
Income Tax
TaxPub Creative Cell
Claim of disallowance in expense in deductions under section 80IB raised afresh in appeal
Income Tax
TaxPub Creative Cell
Capital gains on imputing shareholding into an existing firm and then revaluation of firm and then conversion into a company and subsequent sale to a third party--Whether colorable transaction
Income Tax
TaxPub Creative Cell
Actuary valued post retirement medical benefits scheme--Allowability
Income Tax
TaxPub Creative Cell
TP additions and MAP impact
Income Tax
TaxPub Creative Cell
Indexation beginning from year of bequest or 1-4-1981
Income Tax
TaxPub Creative Cell
Deemed dividend arising out of a de-merger
Income Tax
TaxPub Creative Cell
Explanation to section 73 of the Act by Finance (No. 2) Act, 2014 whether retrospective
Income Tax
TaxPub Creative Cell
Provisions made--Allowability
Income Tax
TaxPub Creative Cell
Measures to eliminate revenue appeals being dismissed at admission stage itself
Income Tax
TaxPub Creative Cell
Section 40a(i) whether discriminatory to article 26(3) of Indo-US DTAA
Income Tax
TaxPub Creative Cell
Charitable activities--Buying and selling whether hit by proviso to section 2(15), requirement to maintain separate set of books section 11(4A). Impact of section 13(8)
Income Tax
TaxPub Creative Cell
Turnover for commodity derivatives under section 44AB. Penalty for failure to get accounts audited under section 44AB.
Income Tax
TaxPub Creative Cell
Effect of fraud of earlier years considered in subsequent years
Income Tax
TaxPub Creative Cell
Accrual of income method consistently followed--Concealment penalty levied whether sustainable
Income Tax
TaxPub Creative Cell
"Full value of the sale consideration" does it refer to actual consideration received only or even deemed consideration under section 50C
Income Tax
TaxPub Creative Cell
Valuation of stamp authority v DVO fair market value on sale date - which one to be adopted.
Income Tax
TaxPub Creative Cell
Ad hoc disallowance on En-route expenses and on sale of scrap trucks
Income Tax
TaxPub Creative Cell
TDS applicability on no VAT charged invoices
Income Tax
TaxPub Creative Cell
Addition under section 69 unexplained investments based on AIR
Income Tax
TaxPub Creative Cell
Penalty under section 221 - does is warrant an order under section 143(1) or 143(3) for assessee to be held in default
Income Tax
TaxPub Creative Cell
Allowability of business expenditure with alternate plea to claim under section 80G
Income Tax
TaxPub Creative Cell
ESOP buy back reimbursed to Trust whether allowable expenditure
Income Tax
TaxPub Creative Cell
Existence of business income whether factually correct
Income Tax
TaxPub Creative Cell
Whether service tax forms part of sums received under section 44B for shipping business of a non-resident
Income Tax
TaxPub Creative Cell
Addition of unexplained investment sale by averaging acquisition price
Income Tax
TaxPub Creative Cell
Reopening an assessment on grounds of prejudicial to the interests of the revenue on various grounds
Income Tax
TaxPub Creative Cell
Sign in bonus--Repaid by subsequent employment--Addition whether sustainable
Income Tax
TaxPub Creative Cell
Section 80IA benefit in a block of 10 consecutive years whether choice at option of assessee.
Income Tax
TaxPub Creative Cell
Date of reckoning of ESOP’s whether grant date or vesting date--Rectification of mistake on face of record of ITAT order.
Income Tax
TaxPub Creative Cell
Payment of commission and ex gratia to directors whether hit by section 36(1)(ii)
Income Tax
TaxPub Creative Cell
Section 50C application where returned value is more than
Income Tax
TaxPub Creative Cell
Allowability of interest to sister concerns
Income Tax
TaxPub Creative Cell
TDS under section 194I applicability on lease premium
Income Tax
TaxPub Creative Cell
Additions to fixed assets made for less than 180 days and additional depreciation claimed under section 32(1)(iia). Whether assessee was eligible for additional depreciation in the subsequent assessment year
Income Tax
TaxPub Creative Cell
Management fee with only marginal improvement in revenue--Disallowance thereof Depreciation on non-compete fee--Pendency of appeal to disallow whether possible
Income Tax
TaxPub Creative Cell
Whether the said drug manufacturing and marketing right was granted after complying with clincal trials
Income Tax
TaxPub Creative Cell
Allowability of forex hedging losses
Income Tax
TaxPub Creative Cell
Upfront receipt by discounting of IDBI bonds, income whether spread over
Income Tax
TaxPub Creative Cell
Assessability whether under section 44BB or section 44DA
Income Tax
TaxPub Creative Cell
Payment for 2D/3D seismic reporting/assessment whether subject to TDS
Income Tax
TaxPub Creative Cell
Depreciation on leased vehicles
Income Tax
TaxPub Creative Cell
Project PE duration how reckoned
Income Tax
TaxPub Creative Cell
Commencement of business cut off and interest taxation prior to commencement
Income Tax
TaxPub Creative Cell
Payment for professional consulting whether subject to TDS thus disallowable under section 40(a)(ia)
Income Tax
TaxPub Creative Cell
Validity of Re-assessment consequential to rent revision with retrospective effect
Income Tax
TaxPub Creative Cell
Addition of share capital and unusually high share premium under section 68
Income Tax
TaxPub Creative Cell
Addition on alleged bogus sale under section 68 adjusted by share allotments
Income Tax
TaxPub Creative Cell
Service tax whether part of section 44BB scope
Income Tax
TaxPub Creative Cell
TP adjustment in freight forwarding agency v. step down sub-agency agreement
Income Tax
TaxPub Creative Cell
TDS on hire purchase
Income Tax
TaxPub Creative Cell
Penalty under section 272A(2)(k)
Income Tax
TaxPub Creative Cell
Reasonable cause for levy of penalty under section 271C
Income Tax
TaxPub Creative Cell
Dividend from offshore entity whether taxable and whether relief under DTAA is available
Income Tax
TaxPub Creative Cell
Slump sale or itemized sale
Income Tax
TaxPub Creative Cell
Section 80M pass through dividend v section 115O(5)
Income Tax
TaxPub Creative Cell
TDS credit due to delay in receipt of form 16A--Rectification thereof
Income Tax
TaxPub Creative Cell
TDS on Passenger service fee (PSF) and amounts held back by credit card companies
Income Tax
TaxPub Creative Cell
Reassessment on question of share acquisition not being at fair value
Income Tax
TaxPub Creative Cell
Allowability of application software expenditure
Income Tax
TaxPub Creative Cell
Existence of a PE in a turnkey contract
Income Tax
TaxPub Creative Cell
Bonus allotment whether hit by section 56(2)(vii)
Income Tax
TaxPub Creative Cell
Rectification on reassessment on point of original assessment whether time barred
Income Tax
TaxPub Creative Cell
Charitable activity section 2(15) explained
Income Tax
TaxPub Creative Cell
Income whether taxable under section 44BB or 115A
Income Tax
TaxPub Creative Cell
Cross border payment for web hosting services whether subject to TDS
Income Tax
TaxPub Creative Cell
Section 14A disallowance whether can be added back for MAT provisions
Income Tax
TaxPub Creative Cell
Deduction under section 80IC due to revised back dated CA certificate
Income Tax
TaxPub Creative Cell
Disallowance of depreciation on goodwill and interest free funds advanced to subsidiaries.
Income Tax
TaxPub Creative Cell
Foreign news agency collection and dissemination of information within India - whether royalty?
Income Tax
TaxPub Creative Cell
Allowability under section 35AD
Income Tax
TaxPub Creative Cell
Addition under section 68 on sale of shares in a stock exchange subject to STT
Income Tax
TaxPub Creative Cell
Levy of penalty under section 271G due to delay in submitting TP documentation
Income Tax
TaxPub Creative Cell
Business income or other sources
Income Tax
TaxPub Creative Cell
Scope of section 245
Income Tax
TaxPub Creative Cell
MAT credit to consider surcharge and education cess
Income Tax
TaxPub Creative Cell
Allowability of bad debt in chit fund business
Income Tax
TaxPub Creative Cell
Waiver of loan principal portion - whether subject to tax under section 28(iv)
Income Tax
TaxPub Creative Cell
Company into software development with comparable into Software development and ITES are not same
Income Tax
TaxPub Creative Cell
Section 45(4) implication on relinquishment of existing partners in favour of a company
Income Tax
TaxPub Creative Cell
Retrospective application causing impossibility of performance - whether disallowance required
Income Tax
TaxPub Creative Cell
Property or business income
Income Tax
TaxPub Creative Cell
Service of notice of reassessment for validation of proceedings
Income Tax
TaxPub Creative Cell
Forfeiture of convertible share warrants whether a short term capital loss
Income Tax
TaxPub Creative Cell
Tips to employee whether subject to TDS
Income Tax
TaxPub Creative Cell
Concealment penalty in TP addition under section 271(1)(c) explanation 7.
Income Tax
TaxPub Creative Cell
Disallowance of expense due to non-deduction of TDS on camera attendants hired on adhoc basis.
Income Tax
TaxPub Creative Cell
Performance warranty given by offshore parent whether interest subject to TDS
Income Tax
TaxPub Creative Cell
Concealment penalty tests/conditions for upholding levy
Income Tax
TaxPub Creative Cell
Writ remedy whether possible after participating in reassessment proceedings
Income Tax
TaxPub Creative Cell
Exemptions under section 10(23C)(iiiab) conditions
Income Tax
TaxPub Creative Cell
TP addition of royalty at NIL in the case of a deemed AE
Income Tax
TaxPub Creative Cell
Peak credits in multiple banks how recknoned.
Income Tax
TaxPub Creative Cell
Allowability of commission expense on overlapping basis without accounting of sale
Income Tax
TaxPub Creative Cell
Buy back whether re-characterized as dividend
Income Tax
TaxPub Creative Cell
Buy back whether recharacterized as dividend
Income Tax
TaxPub Creative Cell
TDS on distributor/stockist discount and on director’s sitting fees for period prior to 1-7-2012
Income Tax
TaxPub Creative Cell
Penalty under section 271G when imposable
Income Tax
TaxPub Creative Cell
Purchase of computer hardware found to be bogus whether additions sustainable?
Income Tax
TaxPub Creative Cell
Expenditure incurred to restructure debt and source strategic investor
Income Tax
TaxPub Creative Cell
Sales return, discount claimed and allowability of expense arising out of subsequent year order
Income Tax
TaxPub Creative Cell
Replacement of key machinery parts whether current repairs
Income Tax
TaxPub Creative Cell
Penalty under section 271C if quantum assessment fails
Income Tax
TaxPub Creative Cell
Additions in TP due to customs valuation on imports from AE
Income Tax
TaxPub Creative Cell
Concealment penalty with defective show cause
Income Tax
TaxPub Creative Cell
Unproven additions under section 68
Income Tax
TaxPub Creative Cell
Application of explanation 3 to section 43(1)
Income Tax
TaxPub Creative Cell
TP addition on reimbursement of promotional expenditure of AE’s--Whether a limited role agent or more larger of that of a marketing agent
Income Tax
TaxPub Creative Cell
PMS scheme whether business income or capital gains
Income Tax
TaxPub Creative Cell
Inclusion of irrelevant comparable in TP
Income Tax
TaxPub Creative Cell
TP addition based on irrelevant comparables
Income Tax
TaxPub Creative Cell
Addition under section 68 for share capital
Income Tax
TaxPub Creative Cell
Compensation when accruing
Income Tax
TaxPub Creative Cell
Deferred consideration in capital gains
Income Tax
TaxPub Creative Cell
Disallowance under section 14A unwarranted if shares are held as stock in trade
Income Tax
TaxPub Creative Cell
Share capital addition as unexplained cash credit
Income Tax
TaxPub Creative Cell
TDS applicability on reimbursement of secondment charges
Income Tax
TaxPub Creative Cell
Interest paid for acquiring shares, whether eligible to be forming cost of acquisition and eligible for indexation
Income Tax
TaxPub Creative Cell
Disallowance under section 40A (3) whether independent of presumptive taxation
Income Tax
TaxPub Creative Cell
Chamber of commerce whether hit by proviso to section 2(15) post assessment year 2009-10
Income Tax
TaxPub Creative Cell
Stay petition in the case of disproportionate demand
Income Tax
TaxPub Creative Cell
Re-characterization of income and potential future income in share capital transaction under TP
Income Tax
TaxPub Creative Cell
Section 40A (3) on net payments and TDS on melting of gold difference
Income Tax
TaxPub Creative Cell
Completed contract method v. Percentage of completion method
Income Tax
TaxPub Creative Cell
Set off of business loss against income from other sources
Income Tax
TaxPub Creative Cell
Deemed dividend amongst closely held companies
Income Tax
TaxPub Creative Cell
Service PE and force of attraction rule
Income Tax
TaxPub Creative Cell
Allowability of expenditure before commissioning of rig but after commencement of business
Income Tax
TaxPub Creative Cell
Notional interest on loans
Income Tax
TaxPub Creative Cell
Notional interest addition
Income Tax
TaxPub Creative Cell
Income from fixed deposit whether business or other sources
Income Tax
TaxPub Creative Cell
EPC contract whether single contract or split and whether PE exists
Income Tax
TaxPub Creative Cell
Claim of rent in a disputed lease
Income Tax
TaxPub Creative Cell
Disallowance under section 14A in case of controlling interest
Income Tax
TaxPub Creative Cell
Receipt of carbon credits whether taxable
Income Tax
TaxPub Creative Cell
Cash credits on advances recovered by a money-lender
Income Tax
TaxPub Creative Cell
Royalty and management fee disallowance in TP
Income Tax
TaxPub Creative Cell
Deemed dividend from group companies under section 2(22)(e)
Income Tax
TaxPub Creative Cell
Depreciation on non-compete fee
Income Tax
TaxPub Creative Cell
Registration of a trust under section 12AA--Rejection
Income Tax
TaxPub Creative Cell
Penalty under section 271D/271E
Income Tax
TaxPub Creative Cell
Corporate guarantees whether international taxation subject to ALP
Income Tax
TaxPub Creative Cell
TP addition of interest on outstanding receivables with AE
Income Tax
TaxPub Creative Cell
Web hosting services whether taxable in the hands of a non-resident
Income Tax
TaxPub Creative Cell
Payment for cross border telecom use of Virtual voice network--An interconnect facility whether royalty under Indo-UK DTAA.
Income Tax
TaxPub Creative Cell
Transfer of loan to another entity whether short term capital loss?
Income Tax
TaxPub Creative Cell
Non-resident whether eligible for proviso 2 to section 48 (i.e. indexation benefit)
Income Tax
TaxPub Creative Cell
Admissibility of additional evidence under rule 46A
Income Tax
TaxPub Creative Cell
Capital gains or business income
Income Tax
TaxPub Creative Cell
Redemption of preference shares post conversion of firm into company to shareholder/partner--Whether dividend under section 2(22)(d)
Income Tax
TaxPub Creative Cell
Payment of settlement compensation through AE, whether extraordinary item to be excluded for ALP calculation.
Income Tax
TaxPub Creative Cell
Pass through costs whether subject to ALP--Cost plus method is gross accounting or net accounting?
Income Tax
TaxPub Creative Cell
TDS for barge transportation in container whether under section 194I or 194C
Income Tax
TaxPub Creative Cell
Enhanced consideration on sale of shares arising due to delay whether interest and taxable in India in the hands of a non-resident.
Income Tax
TaxPub Creative Cell
Revaluation of assets before conversion of firm to company, claim of depreciation on intangible assets
Income Tax
TaxPub Creative Cell
Rectification of interest on refund of income tax whether feasible
Income Tax
TaxPub Creative Cell
Rectification scope
Income Tax
TaxPub Creative Cell
Concealment penalty for MAT provisions
Income Tax
TaxPub Creative Cell
Capital gain or business income
Income Tax
TaxPub Creative Cell
Concealment penalty whether leviable
Income Tax
TaxPub Creative Cell
Levy of penalty for wrong stock estimation and VAT payment
Income Tax
TaxPub Creative Cell
Waiver of loan which was convertible into preference shares whether taxable under section 41(1) or 28(iv)
Income Tax
TaxPub Creative Cell
Disallowance under section 14A with no tax exempt income and investments made due to business expediency
Income Tax
TaxPub Creative Cell
Sale of Basic engineering design specification (BEDS) whether subject to TDS as royalty/FTS
Income Tax
TaxPub Creative Cell
Disallowance under section 14A on interest on borrowing which is invested in firms
Income Tax
TaxPub Creative Cell
Payment of indemnity whether expenditure wholly concerned with transfer of shares
Income Tax
TaxPub Creative Cell
Allowability of Keyman insurance in the wake of IRDA guidelines
Income Tax
TaxPub Creative Cell
Payment to group parent for allotment of ESOP allowability with FBT applied only on vested portion
Income Tax
TaxPub Creative Cell
Business expenditure allowability of software used for operations
Income Tax
TaxPub Creative Cell
Sharing of income between non-resident parent and Indian branch
Income Tax
TaxPub Creative Cell
Whether non-resident firm can fall in the scope of section 144C(15)(b)
Income Tax
TaxPub Creative Cell
Royalty to parent whether allowable under TP
Income Tax
TaxPub Creative Cell
Write-off of vendor advance for non-supply of goods allowability thereof
Income Tax
TaxPub Creative Cell
Unexplained expenditure v Unexplained investment
Income Tax
TaxPub Creative Cell
Section 234E levy prior to 1-6-2015
Income Tax
TaxPub Creative Cell
TDS whether under section 194C or 194J
Income Tax
TaxPub Creative Cell
Employee contribution of PF whether covered under section 43B(b) thus allowable if paid before filing return of income
Income Tax
TaxPub Creative Cell
Transaction fee by members to stock exchange whether fee for technical services subject to TDS. Meaning of Technical fees in section 9(1)(vii)
Income Tax
TaxPub Creative Cell
TP adjustment on ECB
Income Tax
TaxPub Creative Cell
Applicability of TDS on THC/IHC paid to shipping lines, custom agents was subject to TDS under section 194C
Income Tax
TaxPub Creative Cell
Discount to sister concern whether commission subject to TDS under section 194H
Income Tax
TaxPub Creative Cell
Addition under section 69C due to impairment of goodwill on acquisition of a business.
Income Tax
TaxPub Creative Cell
TP benchmarking for a job worker
Income Tax
TaxPub Creative Cell
Notional fair value whether taxable under section 56(2)(viii) or in the alternative be taxed as under section 69/69B
Income Tax
TaxPub Creative Cell
Dividend income under Indo Malaysian DTAA under old treaty/new treaty--Para 10
Income Tax
TaxPub Creative Cell
Addition under section 68 for share capital invested by a non-resident
Income Tax
TaxPub Creative Cell
Penalty under section 271B levy
Income Tax
TaxPub Creative Cell
Income whether business or capital gains
Income Tax
TaxPub Creative Cell
Sale of hardware machine with its embedded software, whether embedded software is royalty taxable in India
Income Tax
TaxPub Creative Cell
Addition made on account of non-distinguishing texture of the by-product
Income Tax
TaxPub Creative Cell
Error in E-TDS system process issues not to penalize assessee
Income Tax
TaxPub Creative Cell
Compensation for cancellation of a contract whether capital or revenue receipt - principles determining compensation is of capital or revenue nature
Income Tax
TaxPub Creative Cell
Whether buy back is a scheme of reorganization is entitled to DTAA benefit under Indo Netherlands DTAA article 13(5)
Income Tax
TaxPub Creative Cell
Capital gains from ESOP whether short term or long term
Income Tax
TaxPub Creative Cell
Whether supply management services with mark-up is subject to TDS under section 195?
Income Tax
TaxPub Creative Cell
Sale of bought out software by a software reseller is not subject to TDS both within India or outside India
Income Tax
TaxPub Creative Cell
Shares sold outside India taxability in India, clubbing provisions in the hands of a non-resident in the hands of his wife a resident in India
Income Tax
TaxPub Creative Cell
Limitation for proceedings under section 201(1) for assessment year prior to insertion of section 201(3) vide Finance Act, 2009
Income Tax
TaxPub Creative Cell
Reading of a project PE
Income Tax
TaxPub Creative Cell
Disallowance under section 40(a)(ia) conditions to be met?
Income Tax
TaxPub Creative Cell
Interest on refund of excess dividend distribution tax
Income Tax
TaxPub Creative Cell
Application of TP comparables ignoring turnover filter
Income Tax
TaxPub Creative Cell
Buyback of shares by a closely held company over and above its par value whether it can be read as deemed dividend under section 2(22(d) for assessment year 2011-12?
Income Tax
TaxPub Creative Cell
Demurrage paid a resident to a non-resident shipping line in India whether disallowable if no TDS is done due to applicability of section 172?
Income Tax
TaxPub Creative Cell
Non-obligated Ex gratia on premature cessation of services -- whether taxable?
Income Tax
TaxPub Creative Cell
Reopening under section 263 alleging cost of conversion of leasehold to freehold Nazul land
Income Tax
TaxPub Creative Cell
Assessee in default for non-deduction of TDS under section 201 read with section 192 on Leave Travel Concession where part journey leg is outside India
Income Tax
TaxPub Creative Cell
Disallowance under section 40(a)(ia) on expenditure incurred in earning capital gains
Income Tax
TaxPub Creative Cell
Time reckoning for reinvestment under section 54 -- Whether before return under section 139(1) or under section 139(4) -- Possession not given booking of flat with private builder whether eligible for reinvestment benefit under section 54
Income Tax
TaxPub Creative Cell
Domestic cost sharing agreement whether hit by assessing officer 40(a)(ia) -- Is it a reimbursement not warranting TDS
Income Tax
TaxPub Creative Cell
Payment of licence fee for use of goodwill by a firm of lawyers -- Allowability
Income Tax
TaxPub Creative Cell
Income from agriculture -- Rental income from lease of land for agricultural operations
Income Tax
TaxPub Creative Cell
Capital gains or business income
Income Tax
TaxPub Creative Cell
Disallowance of interest paid for investment in firm under section 14A alleging that no income nor any interest income arose from the partnership firm
Income Tax
TaxPub Creative Cell
FMV substitution for share sale agreement and re-computation of capital gains
Income Tax
TaxPub Creative Cell
Allowability of charitable donations under section 80G vs. Disallowance of the same under CSR (Corporate Social Responsibility) spend (Explanation 2 to section 37(1))
Income Tax
TaxPub Creative Cell
Income from renting of terrace for erection of mobile antenna tower -- Income from other sources or house property?
Income Tax
TaxPub Creative Cell
Reinvestment benefit claim under section 54 on overseas property after due date for filing return under section 139(1)
Income Tax
TaxPub Creative Cell
Reopening by PCIT under section 263 alleging exempted capital gains arose out of penny stocks -- Validity -- Certain key points on powers of reopening by PCIT
Income Tax
TaxPub Creative Cell
Re-assessment made on same points wherein the earlier post-search assessment made being held void -- Validity
Income Tax
TaxPub Creative Cell
Shares held as stock-in-trade and gifted to another corporate -- Taxability at fair value as business income -- Whether corporate can make gift -- Corporate can it be part of family settlement
Income Tax
TaxPub Creative Cell
Taxability of interest waived on debentures with non-residents but offset with a discounted share price -- Default for non-deduction of TDS in the case of non-resident payees -- Time limit reckoning
Income Tax
TaxPub Creative Cell
Recharacterization of Compulsorily Convertible Debentures (CCD) issued to parent and to AE as Equity -- Disallowance of interest there on under TP/SDT provisions
Income Tax
TaxPub Creative Cell
Deemed capital gains under section 50D on transfer of a right to property with consideration thru a self-made affidavit
Income Tax
TaxPub Creative Cell
Notional interest on interest free deposit taxability thereof under income from house property under section 23(1)(a) in a sale and leaseback arrangement
Income Tax
TaxPub Creative Cell
Claim of short-term capital loss on depreciable asset on demolition without effecting transfer under section 50(2)
Income Tax
TaxPub Creative Cell
Business restructuring as gift by a corporate to offshore step down subsidiaries -- Tax evasion by layering -- Transfer pricing adjustments -- Royalty payments to subsidiary by parent whether permissible
Income Tax
TaxPub Creative Cell
Refund of excise whether eligible for deduction under section 80-IB -- Whether it is a taxable income or a capital receipt -- Applicability of MAT on the same
Income Tax
TaxPub Creative Cell
Allowability of interest deduction under section 24(b) on loans rolled over with private borrowing
Income Tax
TaxPub Creative Cell
Tax credit availability under Indo-Japan DTAA Article 23(2) in India on fee for Independent personal services whether debatable
Income Tax
TaxPub Creative Cell
Forfeiture of advances on agreement to sell -- Application of section 56(2)(ix) (inserted w.e.f. 1-4-2015) for prior assessment years
Income Tax
TaxPub Creative Cell
Depreciation on sub-lease arising out of property leasing business -- Whether allowable as inter head set-off?
Income Tax
TaxPub Creative Cell
Share application money is it a capital asset?
Income Tax
TaxPub Creative Cell
Disallowance of year-end provisions voluntarily offered due to non-deduction of TDS and subsequent reversal of the same in the books -- Taxability thereof
Income Tax
TaxPub Creative Cell
Miscellaneous Application on a Miscellaneous Application possibility
Income Tax
TaxPub Creative Cell
International freight forwarding business -- Transfer pricing -- Sustainability of royalty paid to parent -- Disallowance due to non-deduction of TDS on Global Account Manager fees
Income Tax
TaxPub Creative Cell
Demand notice with draft assessment order whether invalidates the assessment?
Income Tax
TaxPub Creative Cell
Resale price method -- Profitability level index -- Huge Expat salaries non-commensurate to turnover
Income Tax
TaxPub Creative Cell
Application of Explanation 10 to section 43(1) on capital support received from Govt. of India to maintain capital adequacy
Income Tax
TaxPub Creative Cell
Receipt of unusually large share premium on preference shares in a start-up entity -- Additions under section 68
Income Tax
TaxPub Creative Cell
Redemption discount on Foreign currency convertible bonds -- Whether taxable
Income Tax
TaxPub Creative Cell
Interest income and commitment fees earned by a German bank -- Taxability in India alleging PE -- Certain concepts on international taxation
Income Tax
TaxPub Creative Cell
Partner paying interest on overdrawn capital but not receiving interest on capital balance where there is a credit despite there being a clause for interest on the partnership deed -- Notional taxability thereof
Income Tax
TaxPub Creative Cell
Method of computing Capital gains on property acquired thru a JDA
Income Tax
TaxPub Creative Cell
Addition of deemed dividend under section 2(22)(e) on net basis
Income Tax
TaxPub Creative Cell
Recalling order of ITAT under section 254(2) on principles of equity despite lapse of limitation
Income Tax
TaxPub Creative Cell
Spend not claimed as expenditure but as pass through whether hit by section 40(a)(i) disallowance
Income Tax
TaxPub Creative Cell
Reimbursement of Seconded employee salaries paid by AE whether subject to TDS disallowance under section 40(a)(i)
Income Tax
TaxPub Creative Cell
Cancellation of property sale agreement and assessee claiming refund of paid taxes by filing a revised return arising out of a reassessment and claiming it as a rectification petition
Income Tax
TaxPub Creative Cell
Revenue from Intermediary services whether subject to FTS clause under Indo-Sweden DTAA?
Income Tax
TaxPub Creative Cell
Clubbing of individual criminal complaints under sections 276-D/276-C/277 on same material and offence
Income Tax
TaxPub Creative Cell
Amount received from partnership firm on retirement whether subject to capital gains under section 45(1)
Income Tax
TaxPub Creative Cell
"Lump-sum payment to secure lease of land rights whether TDS obligations arise under section 194-I on the same as ""rent""?"
Income Tax
TaxPub Creative Cell
Payment of Bonus to Director cum shareholders whether disallowable under section 36(1)(ii) as they were in lieu of dividend
Income Tax
TaxPub Creative Cell
Exempted interest on tax free bonds under section 10(15)(iv)(h) whether taxable under MAT provisions?
Income Tax
TaxPub Creative Cell
Point of accrual of Income of a non-resident as per DTAA
Income Tax
TaxPub Creative Cell
Allowability of section 10AA deduction on suo moto ALP additions offered by the assessee
Income Tax
TaxPub Creative Cell
Allowability of interest expense on compulsorily convertible debentures under TP provisions
Income Tax
TaxPub Creative Cell
Ultra vires of section 40(a)(iib) before High Court
Income Tax
TaxPub Creative Cell
Payment for sponsorship/promotional material to Doctors whether Commission/Brokerage under section 194-H?
Income Tax
TaxPub Creative Cell
Revenue recognition -- Mirror imaging -- TDS credit thereon
Income Tax
TaxPub Creative Cell
Amendment in section 54F whether to be read as singular property or multiple property under a swap of constructed property for land given in a JDA
Income Tax
TaxPub Creative Cell
Reopening under section 263 questioning exempt capital gains based on penny stocks allegations
Income Tax
TaxPub Creative Cell
Allowability of Depreciation on goodwill arising on amalgamation
Income Tax
TaxPub Creative Cell
Indexation whether from date of allotment or from date of possession?
Income Tax
TaxPub Creative Cell
Payments to Tribals whose income is exempt under section 10(26) whether hit by TDS obligation disallowance?
Income Tax
TaxPub Creative Cell
Revenue from Intermediary services whether subject to FTS clause under Indo-Sweden DTAA?
Income Tax
TaxPub Creative Cell
Cancellation of registration of Trust alleging business activity being pursued
Income Tax
TaxPub Creative Cell
"Movie making business -- Amount received from sale of TV rights whether ""receipt on exhibition of film on commercial basis"" under rule 9 of Income Tax Rules"
Income Tax
TaxPub Creative Cell
Interest earned on fixed deposits during pre-commencement of project
Income Tax
TaxPub Creative Cell
Interest earned on fixed deposits during pre-commencement of project
Income Tax
TaxPub Creative Cell
Demand notice with draft assessment order whether invalidates the assessment?
Income Tax
TaxPub Creative Cell
Disallowance of payments in cash under section 40A(3)
Income Tax
TaxPub Creative Cell
Disallowance of payments in cash under section 40A(3)
Income Tax
TaxPub Creative Cell
Project related expenses debited whether subject to TDS under section 40(a)(iii) read with Article 15 (Dependent Personal Services - DPS) of Indo-Dutch DTAA
Income Tax
TaxPub Creative Cell
Taxability of Mesne profits
Income Tax
TaxPub Creative Cell
Taxability of capital contribution in the hands of a firm under section 56(2)(viia) especially when the capital was used for a legitimate layering arrangement to arrive at a desired financial objective
Income Tax
TaxPub Creative Cell
State tax paid overseas whether allowable as a deductible expenditure and is not hit by section 40(a)(ii)?
Income Tax
TaxPub Creative Cell
Time charter cross border hiring of vessel -- Whether royalty under Indo-Singapore DTAA
Income Tax
TaxPub Creative Cell
Denial of benefits of Article 8 exemption to shipping business under Indo Singapore DTAA citing non-taxability in Singapore and invocation of Limitation of benefits (LOB) Article 24
Income Tax
TaxPub Creative Cell
Deductibility of TDS done but not remitted before the end of the financial year on cash basis of accounting
Income Tax
TaxPub Creative Cell
Chargeability of Capital gains on Exchange differences under section 45 on Investment made in Forex
Income Tax
TaxPub Creative Cell
Capital subsidy credited to Capital reserve instead of adjusting against fixed assets as per Explanation 10 to section 43(1)
Income Tax
TaxPub Creative Cell
Shares loaned but not returned -- Sustainability as transfer under capital gains
Income Tax
TaxPub Creative Cell
Amendment in Indo Singapore DTAA clause in between the year whereby the old clause with rate for royalty @ 15% was replaced by a new clause with royalty @ 10%. Which rate to apply?
Income Tax
TaxPub Creative Cell
Payments to overseas attorneys for IP professional consultancy -- Applicability of TDS obligations thereof under IT Act and under various country DTAA's
Income Tax
TaxPub Creative Cell
Non-receipt of rent whether taxable under section 22 when TDS remitted by lessee
Income Tax
TaxPub Creative Cell
Depreciation on revalued intangible trademarks post conversion of Partnership firm into Company under section 47(xiii) -- Applicability of section 43(1) Explanation 3 read with 5th proviso to section 32(1).
Income Tax
TaxPub Creative Cell
Denial of deduction under section 80JJAA in 3rd year subsequent to recruitment year of new employees citing employees working for less than 300 days in first year - retrospective reading of 4th proviso in section 80JJAA
Income Tax
TaxPub Creative Cell
Availing Article 24 Tax credit under Indo-UK DTAA
Income Tax
TaxPub Creative Cell
Insertion of second proviso to section 54EC(1) vide Finance Act, 2014 with effect from assessment year 2015-16 capping total investment to Rs. 50 lakhs is prospective
Income Tax
TaxPub Creative Cell
Insertion of second proviso to section 54EC(1) vide Finance Act, 2014 with effect from assessment year 2015-16 capping total investment to Rs. 50 lakhs is prospective
Income Tax
TaxPub Creative Cell
Special Purpose Vehicle Charges (SPV) and Rehabilitation and recouping (R&R) amounts paid on mining operations under order of Supreme court whether allowable expenditure under section 37(1).
Income Tax
TaxPub Creative Cell
If agent is remunerated at Arm's length price does it absolve further attribution of profits in the hands of the Permanent Establishment (PE) of the non-resident
Income Tax
TaxPub Creative Cell
Sustainability of AMP expenditure under TP provisions
Income Tax
TaxPub Creative Cell
Computerized reservation system in aviation sector -- PE-attribution of income -- DAPE
Income Tax
TaxPub Creative Cell
To Sustain addition under section 56(2)(vii)(b)(ii) whether transfer be reckoned from date of agreement or date of registration?
Income Tax
TaxPub Creative Cell
Rejection of Books of Accounts
Income Tax
TaxPub Creative Cell
Satellite transponder -- Whether royalty under Indo-UK DTAA -- Land Earth Station (LES) whether a place PE -- Static vs. Ambulatory approach of reading DTAA provisions whether empower reading of IT Act amendments into DTAA unilaterally
Income Tax
TaxPub Creative Cell
Additions on share premium sustained under section 56(2)(viib) -- Startup
Income Tax
TaxPub Creative Cell
Payments for subscription of manuals, flight training, route navigation, parts and service bulletins to non-residents -- Whether subject to TDS under section 195
Income Tax
TaxPub Creative Cell
Benchmarking Management/Support fees as NIL under Transfer pricing provisions -- ALP computation and tolerance
Income Tax
TaxPub Creative Cell
Indirect transfer of shares outside India and taxability of non-resident in India
Income Tax
TaxPub Creative Cell
Sustainability of re-opening under section 147 & 148 -- Summary assessment -- Manually filed revised return ignored by revenue
Income Tax
TaxPub Creative Cell
Share premium utilized to wipe of accumulated losses under court approval -- Taxability under MAT
Income Tax
TaxPub Creative Cell
Sale of Copyrighted article v. Copyrighted under DTAA
Income Tax
TaxPub Creative Cell
Disallowance under section 14A on interest on capital paid to partners of a firm
Income Tax
TaxPub Creative Cell
Dividend distribution tax rate in section 115-O does it override DTAA rates (Indo-German)
Income Tax
TaxPub Creative Cell
Rectification of order route used for sustaining additions post scrutiny assessment -- Validity
Income Tax
TaxPub Creative Cell
Retrospective amendment in law -- Imposing TDS obligations
Income Tax
TaxPub Creative Cell
Allowability of employees exclusively for PE of a foreign bank under head office expenditure under section 44C
Income Tax
TaxPub Creative Cell
Section 40(a)(ia) disallowances in the case of presumptive income under section 44AD
Income Tax
TaxPub Creative Cell
Levy of penalty under section 271AA for non-maintenance of TP documentation on non-resident
Income Tax
TaxPub Creative Cell
Lower rate deduction of TDS on immovable property in case of non-resident -- Levy of penalty thereof
Income Tax
TaxPub Creative Cell
TP adjustment of notional interest whether hit by DTAA Article No. 11 of Indo Cyprus DTAA
Income Tax
TaxPub Creative Cell
Additions under section 56(2)(ix) for advances given for stock-in-trade in real estate business
Income Tax
TaxPub Creative Cell
Disallowance under section 40(a)(ia) for non-deduction of TDS under section 194-I on room bookings in a club
Income Tax
TaxPub Creative Cell
Divergence in treatment of Leases by lessee under AS-19 -- Invocation of section 263
Income Tax
TaxPub Creative Cell
Taxability of reversal of an impairment provision of an Asset Reconstruction Trust as income of an AOP citing an irrevocable trust existence with no definite share with pass thru mechanism under question by revenue
Income Tax
TaxPub Creative Cell
Invocation of section 263 revision powers of Commissioner in a case of limited scrutiny assessment under section 143(3)
Income Tax
TaxPub Creative Cell
Amount credited to Partner's capital account prior to retirement for goodwill whether taxable as capital gains with cost of acquisition as per section 55(2)(a) as NIL.
Income Tax
TaxPub Creative Cell
Alleged Owelty in a Family Settlement vs. Capital gains
Income Tax
TaxPub Creative Cell
Allowability of bad debts under section 37(1) or 28(1)
Income Tax
TaxPub Creative Cell
Additions for annual value for vacant flats held as stock-in-trade -- Per section 23(5) introduction years
Income Tax
TaxPub Creative Cell
Deduction under section 10A/10AA is it prior to set off of carry forward losses or vice versa?; Buy back expenses whether allowable as a business expenditure?
Income Tax
TaxPub Creative Cell
Income if excluded under DTAA would it cover losses as well thus question of allowability of carry forward losses of Capital gains there in
Income Tax
TaxPub Creative Cell
Exempted incomes under section 10 whether excluded from MAT computation?
Income Tax
TaxPub Creative Cell
Attribution of profits in the hands of the non-resident -- Dependent Agency PE (DAPE) alleging Exclusive agency relationship
Income Tax
TaxPub Creative Cell
Taxability of reversal of an impairment provision of an Asset Reconstruction Trust as income of an AOP citing an irrevocable trust existence with no definite share with pass thru mechanism under question by revenue
Income Tax
TaxPub Creative Cell
Claim of reimbursement -- Not hit by section 40(a)(i) read with section 195
Income Tax
TaxPub Creative Cell
Alleged alteration of client code modification (CCM) to corner profits -- Reopening thereof
Income Tax
TaxPub Creative Cell
Whether depreciation is mandatory prior to CIT v. Mahendra Mills Ltd. (2000) 159 CTR 381 (SC) : 2000 TaxPub(DT) 1304 (SC) given the wording of Explanation 5 to section 32.
Income Tax
TaxPub Creative Cell
Disallowance under section 14A in the books of the foreign bank branch in India on interest paid by Head office -- Head office expenses of the foreign branch of a bank -- TDS disallowance on Nostro account expenses
Income Tax
TaxPub Creative Cell
Allowability of section 10A deduction by raising invoices after year end without amending audited accounts
Income Tax
TaxPub Creative Cell
Additions under section 68 in the case of presumptive taxation under section 44AD
Income Tax
TaxPub Creative Cell
Expat Support services -- Employee salary payment and reimbursement with a mark up to an AE -- Questionability in TP
Income Tax
TaxPub Creative Cell
Reassessment under section 147 post block assessment under section 158BC
Income Tax
TaxPub Creative Cell
Additions made under different head by Commissioner (Appeals) without giving opportunity to assessee under section 251(2) for enhancement
Income Tax
TaxPub Creative Cell
Additions sustained on newspaper reports
Income Tax
TaxPub Creative Cell
Section 40A(3) applicability on spend in cash outside India
Income Tax
TaxPub Creative Cell
Deemed to be an international transaction -- Scope of section 92B(1) and (2)
Income Tax
TaxPub Creative Cell
Retrospective application of Proviso 1 of section 50C
Income Tax
TaxPub Creative Cell
Refund of taxes arising out of MAP -- Credit of taxes arising by way of TDS -- Reading of section 199
Income Tax
TaxPub Creative Cell
Software licence fees -- Whether royalty under Indo-Singapore DTAA -- Unilateral taxation under IT Act without amending DTAA provisions
Income Tax
TaxPub Creative Cell
Revision by PCIT under section 263 pending appeal with Commissioner (Appeals)--Section 56(2)(viib)
Income Tax
TaxPub Creative Cell
Commercial growing of flowering plants for export purpose -- Agricultural income
Income Tax
TaxPub Creative Cell
Disallowance under section 40(a)(i)/(ia) on depreciation claimed
Income Tax
TaxPub Creative Cell
Interest under section 244A on refund of self-assessment tax whether hit by proviso to section 244A(1)(a)
Income Tax
TaxPub Creative Cell
Claim of prior-period expenses in current assessment year alleging claim not made in earlier assessment year on a belated return with certain evidences being controverted
Income Tax
TaxPub Creative Cell
Dead rent payable in years of no manufacturing when mines were non-operational
Income Tax
TaxPub Creative Cell
Addition under section 92C(4) -- Claim of deduction under section 10AA post APA -- Advance Pricing Agreement
Income Tax
TaxPub Creative Cell
Due date of payment of TDS whether it relates to the date of credit or date of deposition
Income Tax
TaxPub Creative Cell
Transfer pricing interest benchmarking on Fully and Compulsorily Convertible Debentures (FCCD) denominated in INR
Income Tax
TaxPub Creative Cell
Notional addition of annual value under income from house property on sub-licensed property
Income Tax
TaxPub Creative Cell
Notional addition of interest on sticky loan to related party
Income Tax
TaxPub Creative Cell
Swapping of shares of amalgamated company in lieu of shares of amalgamating company -- Shares held as capital asset or as stock in trade -- Whether profit accrues on the transfer as capital asset or as business profits -- Taxability thereof
Income Tax
TaxPub Creative Cell
Levy of equalization levy on the PE of a non-resident -- Mutual exclusivity
Income Tax
TaxPub Creative Cell
Reassessment with additions sustained under wrong provisions
Income Tax
TaxPub Creative Cell
Allowability of carry forward of losses arising from long-term capital loss on sale of shares/equity units
Income Tax
TaxPub Creative Cell
Addition under section 56(2)(vii)(b)(ii) for difference in stamp value vs. actual consideration of purchased immovable property
Income Tax
TaxPub Creative Cell
Exempted long-term capital gains on sale of shares--Addition under section 68 alleging price rigging arising out of third party statement
Income Tax
TaxPub Creative Cell
Reinvestment allowance under section 54F--Co-ownership--Transfer of property held prior to sale--Alleged afterthought--Tax evasion
Income Tax
TaxPub Creative Cell
Disallowance of earnest money deposit in the hands of a real estate businessman
Income Tax
TaxPub Creative Cell
Capital gains computation vs. Intra head adjustments
Income Tax
TaxPub Creative Cell
Revision powers under section 263 invoked for the second time on the same topic--Whether permissible--Addition of share capital with large share premium therein
Income Tax
TaxPub Creative Cell
Bonus issue expenses allowability
Income Tax
TaxPub Creative Cell
Questioning legality of assessment process under section 144C
Income Tax
TaxPub Creative Cell
Additions sustained under section 68 where amounts were not received in the assessment year of appeal
Income Tax
TaxPub Creative Cell
Existence of PE -- Movie production -- Alleged of default in TDS
Income Tax
TaxPub Creative Cell
Sustainability of addition under section 56(2)(viib) of share premium
Income Tax
TaxPub Creative Cell
Transfer pricing addition in freight forwarding business applying Berry ratio
Income Tax
TaxPub Creative Cell
Taxability of Sale of carbon credits Certified Emission Reduction (CER) receipt
Income Tax
TaxPub Creative Cell
Bogus purchase of machinery -- Addition under section 69
Income Tax
TaxPub Creative Cell
Disallowance of depreciation on block of assets -- Converted into stock-in-trade
Income Tax
TaxPub Creative Cell
Search and seizure -- Additions on alleged incriminating evidences/documents -- Sustainability
Income Tax
TaxPub Creative Cell
Validity of revision powers of Commissioner on erroneous claim of depreciation on alleged intangible asset
Income Tax
TaxPub Creative Cell
Assessment in the hands of a non-existent entity
Income Tax
TaxPub Creative Cell
Sales Promotional spend to doctors -- CBDT circular validity/retrospectivity -- Section 37(1) explanation thereto.
Income Tax
TaxPub Creative Cell
Depreciation on goodwill arising out of a Business transfer agreement dated 20-6-2008 (Assessment Year 2009-10) without claiming it in return but raising the claim before assessing officer for the first time--Allowability.
Income Tax
TaxPub Creative Cell
1. Alternate claim of expenditure incurred to increase authorised capital under section 35D instead of section 37(1), 2. Allowability of legal and professional expenses for an aborted IPO.
Income Tax
TaxPub Creative Cell
APA roll back on IT/ITES services and claim of section 10AA SEZ benefit thereon
Income Tax
TaxPub Creative Cell
Amalgamation in the nature of purchase under court approval -- Sale of shares and capital gains claimed exempt -- MAT treatment -- Question of colourable transaction alleging tax evasion
Income Tax
TaxPub Creative Cell
Taxability of amount received arising out of a sub-licensee's right being relinquished
Income Tax
TaxPub Creative Cell
Stay powers of ITAT -- Effect of writ questioning constitutionality under Article 226(2) of Constitution of India
Income Tax
TaxPub Creative Cell
Suo moto rejection by Commissioner (Appeals) against rectification done by assessing officer to his assessed return in an appeal
Income Tax
TaxPub Creative Cell
Belated return -- Carry forward of unabsorbed depreciation under section 32(2) vs. carry forward of business loss interplay
Income Tax
TaxPub Creative Cell
Disallowance under section 40A(2)(b) of royalty paid to AE (Associated enterprise) of assessee controverting previous year royalty amounts. Interplay of section 40A(2)(b) vs. TP provisions.
Income Tax
TaxPub Creative Cell
Composite letting out whether income from house property or income from other sources?
Income Tax
TaxPub Creative Cell
Time limits amended in section 201(3) vide Finance Act 2 of 2014 with effect from 1-10-2014 are these retrospective or prospective?
Income Tax
TaxPub Creative Cell
Alleged additions from offshore bank account unearthed in an investigation about Offshore bank accounts with stashed money. Averments proving ownership to assessee -- assessee providing wishy washy rejoinders -- Whose money is it?
Income Tax
TaxPub Creative Cell
Disallowance due to non-deduction of TDS on purchase of goods with AE's arising out of a survey alleging PE existence -- Non-discrimination clause of DTAA.
Income Tax
TaxPub Creative Cell
Income from business or other sources -- Cessation of business as sick company and leasing of assets in joint operation -- Res judicata principles
Income Tax
TaxPub Creative Cell
Reinvestment benefit under section 54 -- Allowability -- Assessee selling two houses and acquiring one residential property
Income Tax
TaxPub Creative Cell
Denial of charitable purpose exemption due to commercial activities referring to section 11/12 read with section 2(15) proviso -- Detailed discussion on this topic
Income Tax
TaxPub Creative Cell
Post search return filed under section 153A had increased losses due to correction of error noticed in original return --- Whether can be considered by assessing officer/Commissioner (Appeals)?
Income Tax
TaxPub Creative Cell
Notice for default in deduction of TDS beyond 6 years on non-resident under section 201(3) validity thereof
Income Tax
TaxPub Creative Cell
Profit in lieu of salary under section 17(3) -- Non-compete fee paid to non-resident employees -- TDS default applicability -- DTAA Article 16 scope
Income Tax
TaxPub Creative Cell
Developmental rights transferred by civil contractor with part consideration received in assessment year and offered as business income and possession given -- Applicability of capital gains section 2(47)(v) thereof.
Income Tax
TaxPub Creative Cell
Capital gains levy on cancellation of sale deed due to non-payment of consideration -- Section 53A of Transfer of Property Act, 1882 interplay -- real income concept in capital gains
Income Tax
TaxPub Creative Cell
Reckoning of turnover, how to be applied in case of intra day trade for section 44AB -- Levy of penalty under section 271B thereof
Income Tax
TaxPub Creative Cell
Education or higher education cess whether an allowable business expenditure not hit by Section 40(a)(ii) Expenses expressly disallowable
Income Tax
TaxPub Creative Cell
Non-resident entity -- Reassessment alleging Place and Agency PE (Permanent Establishment) of its BPO Indian entity bereft those points raised and dealt in scrutiny assessment.
Income Tax
TaxPub Creative Cell
Carry forward and set off loss on de-merger by filing revised return -- Decision in favour of assessee
Income Tax
TaxPub Creative Cell
Explanation 2 to section 263 scope explained
Income Tax
TaxPub Creative Cell
Retrospectivity of Proviso 3 to section 50C(1) thereof
Income Tax
TaxPub Creative Cell
Disallowance due to non-deduction of TDS under section 40(a)(i) on overseas guarantee commission -- thereof
Income Tax
TaxPub Creative Cell
Concealment Penalty under section 271(1)(c) - assessment order mentioning reason for penalty but notice under section 271(1)(c) not clearly mentioning it - quashing of penalty levy thereof on grounds of incorrect notice issuance
Income Tax
TaxPub Creative Cell
Alleged existence of PE and attribution of income on a set of composite contracts - with part of it possibly creating PE subsequently cancelled and rest of the income exclusively coming under scope of Fee for Technical Services (FTS).
Income Tax
TaxPub Creative Cell
TDS Obligation on import of goods alleged thru a business connection of a non-resident
Income Tax
TaxPub Creative Cell
Port terminal operator claiming deduction under section 80-IA
Income Tax
TaxPub Creative Cell
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