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Whether depreciation is allowable with respect to the block of assets and not the individual assets
ACIT. Vs. SOUTH ASIA TYRES LTD.
(2014) TaxCorp(LJ) 4148 (ITAT-PUNE) · Income Tax - Sections 2(11), 32, 43, 143(3)
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HC – Conditions for allowability of Secret Commission
CIT vs M/s.Transport Corporation of India
(2014) TaxCorp(LJ) 4147 (HC-AP)
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Whether when no part of the work was undertaken outside Singapore which was to be carried out on a turnkey basis, the appellant ONGC's claim for deduction of taxes is legally sustainable when no taxes were payable as per the provisions of the Indian Income Tax Act
ONGC LTD. Vs WESTERN GECO INTERNATIONAL LTD
(2014) TaxCorp(LJ) 4146 (SC)
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Whereas, the assessee claimed that the said amount was not taxable in the hands of the assessee company in India as the marketing services for which the said amount was given did not make available (technical knowledge, skill, know-how etc.) within the meaning of the Double Taxation Avoidance Agreement (DTAA) between India and the USA.
KANBAY INCORPORATED. Vs. DDIT
(2014) TaxCorp(LJ) 4145 (ITAT-PUNE) · Income Tax - Sections 5(2), 9, 143(3), 144C(13)
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Whether AO could refer a matter of international transaction to the TPO without arriving at a conclusion of objective necessity for referring such matter u/s 92CA(1)
NIHILENT TECHNOLOGIES PVT LTD. Vs. DCIT
(2014) TaxCorp(LJ) 4144 (ITAT-PUNE) · Income tax - Sections 92C, 92CA
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Whether even if the transaction had been structured in the manner as suggested by the Revenue, the gains arising to the shareholders of Copal-Jersey from sale of their shares in Copal-Jersey to Moody UK would not be taxable under Section 9(1)(i), as their value could not be stated to be derived substantially from assets in India
DIT. Vs. COPAL RESEARCH LTD.
(2014) TaxCorp(LJ) 4143 (HC-DELHI) · Income tax - Sections 9(1)(i), 90(2), 115JB, 195, 201A, 245N, 245R
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Whether when the assessee has failed to furnish complete data relating to allocation of costs between the AEs, no benchmarking of international transactions can be done in such circumstances
CONTITECH INDIA PVT LTD. Vs. DCIT
(2014) TaxCorp(LJ) 4142 (ITAT-DELHI) · Income Tax - Sections 10(34), 14A, 92CA(3), 143(3), 144C
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Whether when the assessee has inadvertently included any company in the list of comparables, the same can be made a reason to bar the assessee from claiming that it was wrongly included
UNITED HEALTH GROUP INFORMATION SERVICES PVT LTD. Vs ACIT
(2014) TaxCorp(LJ) 4141 (ITAT-DELHI) · Income Tax – Sections 143(3), 144C
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Whether companies involved in the business of investment, merchant banking and corporate finance can be compared to a company engaged in the business of investment advisory activities
CARLYLE INDIA ADVISORS PVT LTD. Vs. DCIT
(2014) TaxCorp(LJ) 4140 (ITAT-MUMBAI) · Income Tax - Sections 92C(1), (2), 143(3), 144C
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Whether when selling expenses incurred by assessee has not led to brand promotion of such product sold by it, can it be brought within the purview of AMP expenses for determining the cost of the international transactions
SHARP BUSINESS SYSTEMS INDIA LTD. Vs. DCIT
(2014) TaxCorp(LJ) 4139 (ITAT-DELHI) · Income Tax - Sections 37(3A), (3B)
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Whether any TDS obligation arises on part of the bank when no capital gain liability arises out of investments made made by non-resident individual in government securities
DIT. Vs. ICICI BANK LTD.
(2014) TaxCorp(LJ) 4138 (HC-BOMBAY) · Income tax - Sections 90
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Whether interference by the Tribunal is warrented in any case where the issue regarding deduction of TDS on remmittances made to a non-resident towards sales commission and advertisement charges, was already decided by the Coordinate Bench and the facts are same as of the present case
ADIT. Vs. SUMIT GUPTA
(2014) TaxCorp(LJ) 4137 (ITAT-JAIPUR) · Income tax - Sections 9(1)(vii)(b), 195, 201(1), 201(1A)
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Whether any TDS liability u/s 195 arises, when the tax authorities have failed to show that the payment received by the non-resident party is liable to tax in India either in terms of Indian Income tax Act or in terms of Indo-US DTAA
RICH GRAVISS PRODUCTS PVT LTD. Vs. ADDL. CIT
(2014) TaxCorp(LJ) 4136 (ITAT-MUMBAI) · Income Tax - Sections 9(1)(vii), 37(1), 40(a)(i), 195
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Whether the DR can be allowed to raise a new ground that receipt in question is FTS, although neither the AO nor the CIT(A) have considered the receipt in question as FTS
SWIBER OFFSHORE MARINE PTE LTD. Vs. ADIT
(2014) TaxCorp(LJ) 4135 (ITAT-DELHI) · Income Tax - Sections 44BB, 271B
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Whether if any disallowance is wrranted the remedy lies with the CIT u/s 263
PURNIMA DUTTA. Vs. ITO
(2014) TaxCorp(LJ) 4134 (ITAT-KOLKATA) · Income Tax - Sections 40(a)(ia), 41(1), 143(3), 147, 148, 195, 263
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Whether services rendered by a non-resident agent for facilitating the export of assessee, can be treated as "fees for technical services"
CIT. Vs. KIKANI EXPORTS PVT LTD.
(2014) TaxCorp(LJ) 4133 (HC-MADRAS) · Income tax - Sections 9, 9(1)(i), 143(3), 195, 263
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Whether when the agreement was not entered into nor service was made nor payment was received in India, even then disallowance u/s 40(a)(i) can be made
DCIT. Vs. EL FORGE LTD.
(2014) TaxCorp(LJ) 4132 (ITAT-CHENNAI) · Income tax - Sections 9, 40(a)(i), 195(2), 201
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Whether when the non-resident assessee fails to furnish all the agreements relating to offshore equipment supply and supervisory contract, the AO cannot be expected to make an objective assessment
SHANGHAI ELECTRIC GROUP COMPANY LTD. Vs. DDIT
(2014) TaxCorp(LJ) 4131 (ITAT-DELHI) · Income tax - Sections 28, 44BBB
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The case was selected for Scrutiny and the AO assessed income at Rs. 16,89,06,810/- under section 143(3) read with section 144C(1). Assessee filed objections before the DRP which dismissed the same.
ENSCO MARITIME LTD. Vs. ADIT
(2014) TaxCorp(LJ) 4130 (ITAT-DELHI) · Income tax - Sections 44AB, 44BB(1), 142(1), 143(2), (3), 144C(13)
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Whether the assessee will be eligible for deduction u/s 54EC, when investment made, in the relavant AY was not within six months from handing over of the possession to the developer by virtue of joint development agreement
S R MADHAVAN (HUF). Vs. ITO
(2014) TaxCorp(LJ) 4129 (ITAT-BANGALORE) · Income Tax - Sections 54, 54EC, 148
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