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Landmark Rulings

Direct Tax landmark rulings

15,824 rulings

  1. ITAT Delhi · 25 Jun 2022
    Whether corporate death of an entity on amalgamation invalidates a tax assessment order ordinarily cannot be determined on a bare application of Section 481 and will depend on facts of each case.

    Dwarka Portfolio Pvt. Ltd Vs Assistant Commissioner of Income Tax

    (2022) TaxCorp(LJ) 29521 (ITAT-DELHI)

  2. ITAT Chennai · 25 Jun 2022
    It could not be said that the business was not set-up since the assessee had procured the land and partially constructed building during the year which was a vital step to commence the business activities for assessee.

    RBL Hotels Private Limited Vs ACIT

    (2022) TaxCorp(LJ) 29520 (ITAT-CHENNAI)

  3. Bombay High Court · 25 Jun 2022
    Revenue’s appeal before ITAT needs to be restored and considered on its own merits in light of observations made in this order and after considering the documents/orders sought to be placed on record through the rectification application.

    Omega Investments and Properties Ltd Vs The Commissioner of Income Tax-3

    (2022) TaxCorp(LJ) 29519 (HC-BOMBAY)

  4. Bombay High Court · 25 Jun 2022
    It is a case where the assessment was sought to be reopened on account of change of opinion, which is not permissible in terms of proviso to Section 147.

    Virbac Animal Health India P. Ltd Vs Assistant Commissioner of Income-tax-3(3)(1)

    (2022) TaxCorp(LJ) 29518 (HC-BOMBAY)

  5. ITAT Bangalore · 25 Jun 2022
    All the primary facts in connection with the deduction claimed by the Assessee were called for in the original assessment on perusal of which, the deduction was granted.

    BIOCON LTD Vs The Joint Commissioner of Income-tax

    (2022) TaxCorp(LJ) 29517 (ITAT-BANGALORE) · Section 35(2AB)

  6. ITAT Delhi · 25 Jun 2022
    Consultancy charges paid for introduction of client located and engaged in the business in India was in the nature of FTS, making assessee liable to withholding tax.

    Hemera India Pvt. Ltd Vs DCIT

    (2022) TaxCorp(LJ) 29516 (ITAT-DELHI)

  7. ITAT Delhi · 12 Mar 2021
    Trade advances, which are in the nature of commercial transactions would not fall within the ambit of the word advance in section 2(22)(e) of the Act.

    Today Hotels Pvt. Ltd. Vs Asstt. Commissioner of Income Tax

    (2022) TaxCorp(LJ) 29509 (ITAT-DELHI) · Section 2(22)(e)

  8. ITAT Mumbai · 12 Mar 2021
    Penalty cannot be automatic and every addition in the assessment proceedings cannot be gate way for levy of penalty.

    Nabors Drilling International Ltd. Vs DCIT

    (2022) TaxCorp(LJ) 29508 (ITAT-MUMBAI)

  9. ITAT Chennai · 12 Mar 2021
    Sufficient cause under the Limitations Act should be construed liberally to advance substantial justice.

    Inscribe Graphics Ltd. Vs The Assistant Commissioner of Income Tax

    (2022) TaxCorp(LJ) 29507 (ITAT-CHENNAI)

  10. ITAT Jaipur · 12 Mar 2021
    The additional evidences filed by assessee in respect of unsecured loan were necessary to adjudicate the grounds of appeal as also on the principle of natural justice.

    Ishika Foods (P) Ltd. Vs The Income-tax Officer

    (2022) TaxCorp(LJ) 29506 (ITAT-JAIPUR)

  11. ITAT Cochin · 12 Mar 2021
    Extending credit to non-members, could not debar PACS from availing deduction u/s 80P.

    Koduvayur Service Co-operative Bank Ltd. Vs Income Tax Officer

    (2022) TaxCorp(LJ) 29505 (ITAT-COCHIN) · Section 80P

  12. ITAT Mumbai · 05 Mar 2021
    Unless a specific exception is provided in the circular w.r.t. penalty also, it could by no means be construed that penalty was to be treated at par with the quantum additions.

    Air Vision Technologies Vs Income Tax Officer

    (2022) TaxCorp(LJ) 29504 (ITAT-MUMBAI)

  13. ITAT Mumbai · 03 Mar 2021
    Discount on issue of ESOP was allowable as deduction u/s.37(1) of the Act as primary object was not to vest capital but to earn profits by securing consistent services of employees.

    Mahindra Lifespace Developers Ltd Vs Dy.CIT

    (2022) TaxCorp(LJ) 29503 (ITAT-MUMBAI) · Section 37(1)

  14. ITAT Bangalore · 03 Mar 2021
    Mere generation of surplus cannot be a reason to deny exemption u/s 11.

    Janodaya Trust Vs ACIT

    (2022) TaxCorp(LJ) 29502 (ITAT-BANGALORE) · Section 11

  15. ITAT Jaipur · 03 Mar 2021
    A bank pass book or bank statement cannot be considered to be a 'book' maintained by the assessee for any previous year for the purpose of Section 68.

    Vishan Swaroop Gupta Vs I.T.O.

    (2022) TaxCorp(LJ) 29501 (ITAT-JAIPUR) · Section 68

  16. ITAT Delhi · 26 Feb 2021
    In the professional field there are innovative ways visualized by the professional to make themselves visible and to build their own professional profile for generating higher and value added business, and such scholarships created is visibility in international arena and his social standing.

    Harish N. Salve Vs ACIT

    (2022) TaxCorp(LJ) 29500 (ITAT-DELHI) · Section 37

  17. Madras High Court · 24 Jun 2022
    Without any substantive material, assessee cannot be construed as owner of the WTGs. Payment made by it to Wescare can be treated only as a consumption charge for electricity supplied to them, for business purpose.

    Tube Investments of India Ltd Vs Commissioner of Income Tax

    (2022) TaxCorp(LJ) 29499 (HC-MADRAS)

  18. ITAT Bangalore · 24 Jun 2022
    Provision of Article 289 is not applicable as the Trust did not fall under Article 12 of the Constitution since it has a separate legal entity distinct from the state.

    Udupi Nirmithi Kendra Vs ACIT

    (2022) TaxCorp(LJ) 29498 (ITAT-BANGALORE) · Section 11

  19. ITAT Mumbai · 26 Mar 2021
    License fee paid for purchases of software is not in the nature of royalty under India-Singapore DTAA and assessee is not liable to deduct TDS u/s 195.

    Reliance Corporate IT Park Ltd Vs DCIT

    (2022) TaxCorp(LJ) 29484 (ITAT-MUMBAI)

  20. ITAT Chennai · 01 Apr 2021
    If funds kept in fixed deposits is having inextricable link with project, then interest earned on short term deposits should be reduced from work in progress, but cannot be assessed under the head income from other sources.

    Hitachi Automotive Systems (India) Pvt. Ltd Vs The Deputy Commissioner of Income Tax

    (2022) TaxCorp(LJ) 29483 (ITAT-CHENNAI)

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