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Last Updated : Friday 19th September, 2014 - 4:55pm
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PEO company
Category Archives: ITAT
   

ITAT

2014-ITS-1538-ITAT-Bank of Tokyo Mitsubishi UFJ Ltd. -Vs- ADIT, Circle-1(1), International Taxation, New Delhi , On. SEPTEMBER  19, 2014 

 Where assessee, a bank incorporated in Japan, paid salaries abroad to its expatriates working in Indian branch constituting PE, in view of fact that said expenditure had been incurred wholly and exclusively for Indian branch and, no part of those expenses could be allocated to any other branch by head office, provisions of section 44C did not apply to said expenditure and thus, assessee’s claim for deduction of salary expenses was to be allowed Continue reading

2014-ITS-1519-ITAT-Jcdecaux Advertising India (P.) Ltd. -Vs- Deputy Commissioner of Income-tax, Circle-4(1) , On. SEPTEMBER  8, 2014 

Where in pursuance of contract awarded by NDMC for construction of Bus Queue Shelters (BQS), assessee entered into manufacturing agreement with third party for manufacture and installation of BQS and also made advance payment, assessee’s business could be said to commence in relevant year and, therefore, revenue authorities were not justified in rejecting assessee’s claim for deduction of certain expenses taking a view that said expenses were in nature of pre-operative expenses as business would be set up in a subsequent year when BQSs would be ready for providing space to assessee for advertisement Continue reading

2014-ITS-1539-ITAT-Hughes Systique India (P.) Ltd. -Vs- Deputy Commissioner of Income-tax, Circle-12 (1), New Delhi , On. AUGUST  29, 2014 

Where TPO made addition to assessee’s ALP in respect of software development services rendered to AE by applying external TNMM, in view of fact that in earlier years Tribunal had remanded matter back with a direction that internal CUP was to be applied, in absence of any change in circumstances, following aforesaid of Tribunal, impugned addition was to be set aside Continue reading

2014-ITS-1540-ITAT-Toluna India (P.) Ltd. -Vs- Assistant Commissioner of Income-tax, Circle 12 (1), New Delhi* , On. AUGUST  26, 2014 

Where TPO made addition to assessee’s ALP in respect of software development services rendered to AE on basis of arithmetic mean of comparables selected by him, in view of fact that some those comparables were inappropriate on account of functional difference, turnover, brand value etc., impugned addition was to be set aside Continue reading

2014-ITS-1541-ITAT-A.T. Kearney India (P.) Ltd. -Vs- Additional Commissioner of Income-tax, Range-1, New Delhi* , On. AUGUST  26, 2014 

Section 10A deduction was to be allowed as mere high profit of person carrying on eligible business is no criteria to deny section 10A benefit and apply deeming provision under section 80-IA(10) Continue reading

2014-ITS-1542-ITAT-Bhagwan Shree Laxmi Narain -Vs- Income-tax Officer (E), Trust Ward-III, Delhi , On. AUGUST  20, 2014 

Assessee trust was established wholly and exclusive for religious purpose, section 115BBC could not be invoked Continue reading

2014-ITS-1520-ITAT-Vijay V. Meghani -Vs- Deputy Commissioner of Income-tax, 23(3) , On. AUGUST  20, 2014

Where assessee filed appeal with a delay of more than eight years against denial of deduction under section 80-O contending that said delay was caused due to advice given by Chartered Accountant to effect that since appeal on similar issue was already pending before Tribunal for earlier year and it was only on basis of decision in said appeal, a rectification application could have been filed before Assessing Officer, it was opined that said absurd advice could not have been given by Chartered Accountant and, therefore, appeal filed belatedly was to be dismissed being barred by limitation Continue reading

2014-ITS-1543-ITAT-Income-tax Officer (TDS), Trivandrum -Vs- Beacon Projects (P.) Ltd.* , On. AUGUST  8, 2014 

Where assessee, a builder, having collected certain booking amount from purchasers of flats, sold those flats subsequently to some other parties at a higher price, amounts refunded by assessee to original purchasers with a margin amounted to payment of interest within meaning of section 2(28A) Continue reading

2014-ITS-1544-ITAT-Income-tax Officer, (International Taxation)-3 (1), Mumbai -Vs- Linklaters & Paines* , On. AUGUST  8, 2014 

Where assessee a U.K. based partnership firm engaged in ‘rendering’ legal services in India had PE in India in terms of article 5(2)(k) of India UK DTAA, profits attributable to PE were taxable under article 7 of India UK DTAA Continue reading

2014-ITS-1545-ITAT-Prithvi Information Solutions Ltd. -Vs- Assistant Commissioner of Income-tax, Circle- 16 (3), Hyderabad* , On. AUGUST  8, 2014 

Investments in nature of equity, cannot be treated as loans and advances and hence cannot be brought within purview of ‘international transactions’ as defined under section 92B Continue reading

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