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As Assessee does not have a permanent establishment in India, the article 7 of the treaty will trigger only if such profits are attributable to a permanent establishment in India.
Taj TV Limited Vs DCIT
(2023) TaxCorp(LJ) 31288 (ITAT-MUMBAI)
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Several notices were issued under Section 142(1) seeking details of deposits made by account holders, however no reference was made to any material or document seized in the course of search in any of the notices.
Renukamat Multi State Coop Urban Credit Soc. Ltd Vs ACIT
(2023) TaxCorp(LJ) 31287 (ITAT-MUMBAI)
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HC - Delhi HC Directs Revenue to Dispose of Assessee's Objections Against Section 153C Notices; Provided important guidelines for the handling of objections against Section 153C.
Kamal Nath Vs DEPUTY COMMISSIONER OF INCOME TAX
(2023) TaxCorp(LJ) 31280 (HC-DELHI) · Section 153C
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Since both the conditions for classification as financial liability failed, the instruments cannot be classified as financial liability and thus, in turn cannot be termed as CFI in absence of the financial liability component.
Reliance Industrial Investment and Holdings Limited Vs DCIT
(2023) TaxCorp(LJ) 31274 (ITAT-MUMBAI)
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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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The question of law framed in the instant appeals is squarely covered.
Google India Pvt Ltd Vs THE COMMISSIONER OF INCOME TAX
(2023) TaxCorp(LJ) 31272 (HC-KARNATKATA)
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Bombay HC is directed to consider the matter afresh in accordance with law and on merits and consider the effect of the omission of Section 144B(9) of the Act.
Mantra Industries Limited Vs NATIONAL FACELESS ASSESSMENT CENTRE (FORMERLY KNOWN AS NATIONAL E-ASSESSMENT CENTRE) & ORS.
(2023) TaxCorp(LJ) 31271 (SC) · Section 144B(9)
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Once the assessees herein are held to be not liable to deduct the tax at source at all merely because subsequently the foreign company VOAMC is held liable to be taxed in India, the assessees herein cannot be treated as assessees in default.
Van Oord Acz India Pvt. Ltd Vs COMMISSIONER OF INCOME TAX-VI
(2023) TaxCorp(LJ) 31270 (SC) · Section 40(a)(i)
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As per provisions of Section 115A(i)(a)(ii), interest income earned by the assessee would be chargeable to tax at 20%.
Cooperative Rabobank UA Vs Deputy Commissioner of Income Tax
(2023) TaxCorp(LJ) 31269 (ITAT-MUMBAI)
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The dates of the transactions in regard to the Benami properties was indeed before coming into force the 2016 Amendment Act.
Parvesh Construction Pvt. Ltd. & ors Vs Union of India & ors.
(2023) TaxCorp(LJ) 31268 (HC-BOMBAY)
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ITAT - Mumbai ITAT Quashes Assessment Order for Non-Conformity with DRP's Finding on Type of PE; Emphasizes Need for 'Complete Conformity' Under Section 144C.
AZZ WSI B.V. Vs The Deputy Commissioner of Income Tax
(2023) TaxCorp(LJ) 31267 (ITAT-MUMBAI)
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Payment for Supervision, Installation, and Commissioning Services Not FTS under India-Belgium DTAA; Invokes MFN Clause under India-Portugal DTAA, Deletes Disallowance under Section 40(a)(i).
Dieffenbacher GmbH Vs The ACIT
(2023) TaxCorp(LJ) 31265 (ITAT-MUMBAI)
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ITAT - While the CIT has the power to consider fresh issues during proceedings under Section 263, a fresh show cause notice must be issued to the Assessee, presenting the new issues for their response.
Samsung C & T Corporation Vs CIT (1nternational Taxation)-3
(2023) TaxCorp(LJ) 31264 (ITAT-DELHI)
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ITAT - Determines Non-taxability of Advertising Rights Payment as Royalty in Cricket Tournaments by considering LoB Clause Applicability.
Total Sports & Entertainment India P. Ltd Vs Income Tax Officer
(2023) TaxCorp(LJ) 31263 (ITAT-MUMBAI)
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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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Witholding of refund due to OYO Hotels & Homes Pvt. Ltd. by the Revenue is bereft of cogent reasons, thus not sustainable.
OYO Hotels And Homes Private Limited Vs DEPUTY ASSISTANT COMMISSIONER OF INCOME TAX & ANR
(2023) TaxCorp(LJ) 31261 (HC-DELHI)
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The payment to the UAE based service provider are in the nature of technical services and not royalty.
Kalpataru Power Transmission Ltd Vs The Dy. CIT
(2023) TaxCorp(LJ) 31260 (ITAT-AHMEDABAD)
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The delay of just one day in uploading the assessment order or generating the DIN cannot make the assessment order unsustainable in law.
Prakash Lal Khandelwal Vs The Commissioner of Income Tax
(2023) TaxCorp(LJ) 31236 (HC-JHARKHAND)
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Reopening of assessment under Section 148 cannot be justified on hypothesis of a future event.
World Sport Group (Mauritius) Limited Vs The DCIT
(2023) TaxCorp(LJ) 31235 (ITAT-MUMBAI)
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The addition on account of interest of Rs.68.49 Cr @ 22% as directed by the DRP is unsustainable.
CPI India Real Estate Ventures Limited Vs Deputy Commissioner of Income-tax
(2023) TaxCorp(LJ) 31228 (ITAT-MUMBAI)
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