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Income Tax - Section 143 - Giving thoughtful consideration to the matter on record and going through the precedent cited it is quite evident that as far as ground no 1 and 2 arising our of the issue of dividend income from investment in the P.E. in Oman is concerned the same being included in the taxable…

Income Tax - Section 147 - The profit attribution in case of PO of the assessee was made merely on the basis of the findings in the case of Alcatel-Lucent France. It is also evident in the assessment order that since the assessee is part of Alcatel-Lucent group and has PE in India the assessing officer…

Income Tax - Sections 143(3), 144C - Segmental details of distribution activities of Dandapani & Co. was filed before the DRP by the assessee. In the interest of justice and equity, direct the assessee to furnish the segmental details of Dandapani & Co. before the AO / TPO to prove its case that the…

Income Tax - Sections - 92A, 143(3), 144C(13) - As far as exclusion of Inteq Software Private Limited is concerned, the first objection of the counsel for the Assessee was that this company is functionally not comparable because it is engaged in the business of computer programming, consultancy and …

Income Tax - Sections 40(a)(ia), 148, 250 - The nature of service rendered by CGTM France to the assessee needs to be examined. The ALH Shakti Engine was co- developed by Turbomeca (a company based at France) and the assessee and the assistance for conducting flight tests were provided by CGTM France…

Income-tax – Section 92CA - This company was engaged in product development and product design and analysis services is functionally different from a pure software service provider and therefore, excluded it from the list of comparables for software development services. The same view was taken in the…

Income Tax - Sections 143(3), 144C(1) - Issue as to whether LIBOR is to be taken as the basis of interest benchmarking for foreign currency denominated loans or whether Indian PLR will be relevant for the same, is no longer res integra. In the case of CIT Vs Tata Autocomp Systems Ltd, it was observed…

Income Tax – Sections 143(3), 144C(13) - The assessee has sought inclusion of all the above said 4 comparable companies before TPO. However, the TPO has commented only on M/s. Esha Media Research Ltd. and it was shown us that the reasoning given by TPO for rejecting this company is against the facts…

Income Tax - Section 143(3) - Both the lower authorities had not considered the contentions of the assessee with regard to incurrence of the vehicle expenses. Ultimately it is a fact that assessee company does not own any vehicles as is evident from the fixed assets schedule of the assessee company …

Income Tax - Sections 92CA, 144 - No reason to take any other view of the matter then the view consistently taken by the coordinate benches including in the case of IPF India Property Cyprus Ltd. vs. DCIT (Supra) wherein speaking on the issue coordinate bench has inter alia observed as follows:- Coming…

Section 9 of the Income-tax Act, 1961 - In this appeal, the issue to he decided is as to whether the AO is justified in disallowing a sum of Rs. 1,15,68,449/-being software charges on the ground of non-deduction of tax at source. The facts and circumstances under which this addition is made by the AO…

Income tax Act - Section 2(11) - It is also contended that the Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015 has introduced a tax compliance provision under Chapter VI of the Act and the Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Rules,…

Income Tax - Sections 9(1)(vii), 40(a)(ia), 195 - The department has accepted the contention that this sum is not disallowable as the subsequent assessment is completed by the department at returned income. Not only that the DR has also not countered the notable argument of the AR of the assessee that…

Based on relevant Articles of the Verein and principles of law as with regard to the question as to if the assessee was operating on the concept of mutuality, the first thing that can be observed is that the Tax Residency Certificate in favour of the assessee issued by authorities specifically mention…

Income Tax - Section 92CA - The expression 'debt arising during the course of business' refers to trading debt arising from sale of goods or services rendered in course of carrying on business. Once any debt arising during course of business is an international transaction, he submitted that any delay…

Income tax - Sections 92CA, 153 - The Delhi Tribunal in case of Honda Trading Corporation Vs. DCIT, it was held that the time limit specified u/s 92CA(3A) is mandatory and not directory and therefore the TPO is bound by the time limit for passing of the order u/s 92CA (3) of the Act. Accordingly, in…

Income Tax - Sections 92CA, 254, 271(1)(c) - The only issue in the present appeal relates to the validity of the penalty levied u/s 271(1)(c) of the Act. The TPO passed an order on 14.12.2020 u/s 92CA(3) r.w.s. 254 of the I.T. Act, 1961 to give effect to ITAT order. Copy of the same was filed by the…

As far as comparable companies chosen by the TPO viz., Maple ESolution Ltd., Vishal Information Technological Services Ltd., Asit C.Mehta Financial Services Ltd., and Gold Stone Infratech Ltd., we find that the Hyderbad Bench of the ITAT in the case of HSBC Electronic Data Processing India Ltd. Vs. …

Income Tax - Sections 143(3), 144C(3) - It was submitted that assessee does not undertake any significant research and development in relation to the transactions under consideration that may have lead to the development of non-routine intangibles. Accordingly, the assessee does not own any significant…

Income-tax - Sections 143(3), 144C - From the annual report of this company, it is observed that this company is not comparable to the profile of assessee. Further it is an accepted position that this company is a giant risk-taking company and is engaged in development and sale of software products …

03-05-2022 News Update
Tax-to-GDP ratio dips for LAC tax jurisdictions

15-04-2022 News Update
Growth losing steam in Europe: OECD CLIs

02-04-2022 News Update
CBDT relaxes provisions of TCS for non-resident visiting India

02-04-2022 News Update
CBDT entered into 62 APAs in last fiscal

19-03-2022 News Update
FDI proposals worth Rs 76K Crore received from neighbouring economies: Govt

19-03-2022 News Update
GDP in G20 area slows down in H2

11-03-2022 News Update
Joblessness stablises at pre-pandemic level in OECD Area

25-02-2022 News Update
G20 trade recovers but growth in services lags

07-02-2022 News Update
Inflation rises to scary height in OECD area - 6.6%

07-02-2022 News Update
India receives USD 54 bn FDI inflow till Nov-end

03-02-2022 News Update
Services trade liberalised in 2021 logs huge dip in volume & effect: OECD

03-02-2022 News Update
Revisionary jurisdiction u/s 263 extended to TPO's order

03-02-2022 News Update
Parity restored for Tax on Dividend earned from foreign companies

03-02-2022 News Update
Tax Benefits to non-resident operating through IFSC

03-02-2022 News Update
Highest ever annual FDI inflow of USD 81.97 bn in 2020-21

GUIDELINES FOR COMPULSORY SELECTION OF RETURNS FOR COMPLETE SCRUTINY DURING FINANCIAL YEAR 2022-23 - PROCEDURE FOR COMPULSORY SELECTION IN SUCH CASES

INSTRUCTION REGARDING IMPLEMENTATION OF JUDGMENT OF HON'BLE SUPREME COURT, DATED 4-5-2022 (UNION OF INDIA V. ASHISH AGARWAL [2022] 138 TAXMANN.COM 64)

INCOME-TAX (FIFTEENTH AMENDMENT) RULES, 2022 - AMENDMENT IN RULE 114; INSERTION OF RULES 114BA AND 114BB

SECTION 119 OF THE INCOME-TAX ACT, 1961 - CENTRAL BOARD OF DIRECT TAXES - INSTRUCTIONS TO SUBORDINATE AUTHORITIES - NOTIFIED AUTHORITIES TO PASS REGISTRATION ORDER FOR TRUSTS, INSTITUTIONS AND FUNDS - AMENDMENT IN NOTIFICATION S.O. 1443(E) [NO. 30/2021/F. NO. 370142/4/2021-TPL], DATED 1-4-2021

INCOME-TAX (FOURTEENTH AMENDMENT) RULES, 2022 - AMENDMENT IN FORM NOS. 3CF, 10A, 10AB AND 10BD; SUBSTITUTION OF FORM NO. 10BE

GUIDELINES UNDER CLAUSE (23FE) OF SECTION 10 OF THE INCOME-TAX ACT, 1961

INCOME-TAX AMENDMENT (THIRTEENTH AMENDMENT) RULES, 2022 - INSERTION OF RULE 2DCA AND FORM NO. 10BBD; SUBSTITUTION OF FORM NOS. 10BBB AND 10BBC

INCOME-TAX (TWELFTH AMENDMENT) RULES, 2022 - AMENDMENT IN RULE 44E; SUBSTITUTION OF FORM NOs. 34C , 34D, 34DA, 34E AND 34EA

Income-tax (10th Amendment) Rules, 2022

INCOME-TAX (ELEVENTH AMENDMENT) RULES, 2022 - INSERTION OF RULE 12AC AND FORM ITR-U

SECTION 10(46) OF THE INCOME-TAX ACT, 1961 - EXEMPTIONS - STATUTORY BODY/AUTHORITY/BOARD/COMMISSION - EXEMPTION FROM SPECIFIED INCOME

SECTION 47 OF THE INCOME-TAX ACT, 1961 - TRANSACTIONS NOT REGARDED AS TRANSFER - ORIGINAL FUND - NOTIFIED COUNTRIES AND TERRITORIES FOR PURPOSE OF CLAUSES (viiac) AND (viiad) OF SAID SECTION

INCOME-TAX (NINTH AMENDMENT) RULES, 2022 - CORRIGENDUM TO NOTIFICATION G.S.R. 307(E) [NO. 37/2022/F.NO. 370142/01/2020-TPL(PART I)], DATED 21-4-2022

REVISED INSTRUCTION FOR CONSTITUTION AND FUNCTIONING OF ‘LOCAL COMMITTEES TO DEAL WITH TAXPAYERS’ GRIEVANCES FROM HIGH-PITCHED SCRUTINY ASSESSMENT

SECTION 280A OF THE INCOME-TAX ACT, 1961, READ WITH SECTION 84 OF THE BLACK MONEY (UNDISCLOSED FOREIGN INCOME AND ASSETS) AND IMPOSITION OF TAX ACT, 2015 - SPECIAL COURTS - DESIGNATED SPECIAL COURT FOR SPECIFIED STATE

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ITAT: Assessee’s plea is allowed to exclude Acropetal Technologies Ltd, Infosys Ltd, and Sasken Communication Technologies Ltd citing unavailability of segmental details, high turnover and brand value and ownership of intangibles.
ITAT: Even if royalty is to be considered independently, the transaction is at arm’s length as compared to the comparables considered by Ld.TPO.
ITAT: Issue is remitted back to AO/TPO for fresh ALP-determination after providing opportunity of being heard to the assesse.
ITAT: The concerned assessee fell within the meaning of eligible assessee as per Sec.144C, since the AO, in its assessment order made additions on account of TP-adjustment proposed by TPO in the order passed u/s.92CA(3).
ITAT: The negative lien did not entail financial commitments on part of the assessee rather imposed a restriction which obliged assessee not to deal in certain specified securities during the tenure of loan.
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