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ITAT - Bangalore ITAT Upholds Revision u/s 263 Due to Lack of Inquiry on Sales Incentives and TDS.
Seiko Watch India Pvt. Ltd. Vs The Principal Commissioner of Income Tax
(2023) TaxCorp(LJ) 32088 (ITAT-BANGALORE)
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The interest income received by the Assessee on temporary short term fixed deposits is eligible for exemption under Section 10AA.
Allstate India Private Limited Vs DCIT
(2023) TaxCorp(LJ) 31718 (ITAT-BANGALORE) · Section 10AA
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Elements necessary for satisfying the make available clause were absent in the services rendered by the Assessee to its Indian customers/clients, thus the same cannot be taxed in India.
Charles River Laboratories Inc. Vs The ACIT
(2023) TaxCorp(LJ) 31686 (ITAT-BANGALORE)
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Interest received by the Assessee cannot be treated as operational income as the interest received does not pertain to credit facilities provided to its members as stipulated in Section 80P(2)(a)(i).
Sangam Coop. Credit Society Ltd Vs The Assessing Officer, National e-assessment Centre
(2023) TaxCorp(LJ) 31582 (ITAT-BANGALORE) · Section 80P
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Rendering of service by the seconded personnel shall not constitute as fees for technical services, in the absence of making available any technical knowledge or skill to the Indian entity.
Juniper Networks Inc. Vs ITO
(2023) TaxCorp(LJ) 31536 (ITAT-BANGALORE)
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All the transactions of the Assessee with its associated enterprise for purchase of online advertisement space has been held to be at arm’s length and therefore, no further profits could be attributed.
Google India Private Ltd Vs The Additional Commissioner of Income Tax
(2023) TaxCorp(LJ) 31273 (ITAT-BANGALORE)
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ITAT - Upholds Reassessment of Wealth Tax, Considers Assessee as 'Owner' of Land without Fulfillment of Conditions under Section 53A of TPA
Triad Resorts and Hotels (P.) Ltd Vs WTO
(2023) TaxCorp(LJ) 31262 (ITAT-BANGALORE)
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The profit margin foregone by the Assessee cannot be held to be an incurred expenditure in creating intangible or goodwill.
Flipkart India Private Limited Vs The Assistant Commissioner of Income Tax
(2023) TaxCorp(LJ) 31161 (ITAT-BANGALORE)
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Amount received by the Assessee from sale of advertisement space through its AdWords program cannot be brought to tax in India as royalty.
Google Ireland Ltd Vs DCIT (IT)
(2023) TaxCorp(LJ) 31092 (ITAT-BANGALORE)
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The Assessee cannot be asked to prove the negative fact that no payments are received during the impugned year in the absence of any positive evidence to the contrary.
Saudi Telecom Company Vs The Assistant Commissioner of Income Tax
(2023) TaxCorp(LJ) 31081 (ITAT-BANGALORE)
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The amount paid by GIPL to the Assessee with reference to seconded employees does not come within the FIS under the Act or DTAA and the addition is liable to be deleted.
Google LLC Vs JCIT (OSD) (IT), DCIT (IT)
(2023) TaxCorp(LJ) 31035 (ITAT-BANGALORE)
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The Assessee cannot be denied the deduction towards application and accumulation of funds and the addition is liable to be deleted.
Mulki Sundar Ram Shetty Nagar Ayyappa Swamy Temple Trust Vs ITO
(2023) TaxCorp(LJ) 31008 (ITAT-BANGALORE)
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It is impermissible for the Revenue to adopt percentage of completion method as against project completion method consistently followed by the Assessee which was undisputed in the prior and subsequent years' assessments.
Corporate Leisure & Property Development Private Limited Vs The DCIT
(2023) TaxCorp(LJ) 30983 (ITAT-BANGALORE)
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Income which is already taxed in the hands of the firm is not taxable in the hands of the partner.
Mulberry Textiles LLP Vs ITO
(2023) TaxCorp(LJ) 30965 (ITAT-BANGALORE) · Section 10(2A)
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Benefit of deduction under Section 32AC is available to only manufacturing sector and not the service sector, thus Infosys is ineligible for Section 32AC deduction.
Infosys Ltd Vs The Joint Commissioner of Income Tax
(2023) TaxCorp(LJ) 30936 (ITAT-BANGALORE) · Section 32AC
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The grounds of the present appeal did not emanate from the FAO, rather emanated from the order dated 21.01.2022, which is ultimately traceable to the order of the Tribunal dated 2013.
IBM India Private Limited Vs The Deputy Commissioner of Income Tax
(2023) TaxCorp(LJ) 30909 (ITAT-BANGALORE)
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The convenience fee retained by Bigtree Entertainment from the end customer cannot lead to an inference that it acts on behalf of the Assessee.
Srinivas Rudrappa Vs The Income Tax Officer
(2023) TaxCorp(LJ) 30813 (ITAT-BANGALORE)
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The reimbursements paid to the Assessee were on cost-to-cost basis and no element of profit was involved therein.
TOYODA Gosei Company Vs Deputy Commissioner of Income-tax
(2022) TaxCorp(LJ) 30676 (ITAT-BANGALORE)
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Payment made to Google Ireland under the Adwords Programme cannot be characterized as royalty under the India-Ireland DTAA.
Google India Private Ltd Vs The JDIT
(2022) TaxCorp(LJ) 30672 (ITAT-BANGALORE)
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If investments made in Infosys BPO which did not yield any exempt income, is excluded from computation as per Rule 8D.
Infosys Ltd Vs The Assistant Commissioner of Income Tax
(2022) TaxCorp(LJ) 30661 (ITAT-BANGALORE) · Section 10AA
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