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Landmark Rulings

Direct Tax landmark rulings

15,824 rulings

  1. ITAT Delhi · 07 Mar 2022
    Payment received by the Swedish company for providing Information Technology services is held not taxable as FTS, by applying restrictive provision of FTS provided in India-Portugal DTAA by invoking MFN clause under India- Sweden DTAA.

    Perfetti Van Melle ICT & BV Vs ACIT

    (2022) TaxCorp(LJ) 28533 (ITAT-DELHI)

  2. ITAT Delhi · 07 Mar 2022
    The action of the learned Assessing Officer was legal and non-production of the persons summoned had rightly led to the inference that the assessee had routed their own money in the books of accounts through the conduit of investor companies.

    Anandtex international P.Ltd Vs ACIT

    (2022) TaxCorp(LJ) 28532 (ITAT-DELHI) · Section 68

  3. Calcutta High Court · 07 Mar 2022
    Registration under Section 25 of the Companies Act is undoubtedly a relevant factor to be noted while considering an application for registration under Section 12AA as registration under Section 25 of the Companies Act recognises the main objectives of the company as a non-profit organisation.

    Creative Museum Designers Vs INCOME TAX OFFICER

    (2022) TaxCorp(LJ) 28531 (HC-CALCUTTA)

  4. ITAT Delhi · 07 Mar 2022
    Resort to section 41(1) could arise only if the liability of the assessee has said to have ceased finally without having possibility of reviving it, which is not the case here.

    ACIT, CIRCLE 2 GHAZIABAD VERSUS M/S SUPREME CERAMICS LIMITED AND VICE-VERSA

    (2022) TaxCorp(LJ) 28530 (ITAT-DELHI) · https://taxcorp.in/FileOpenDT.aspx?ID=95948&Category=ITAT&CategoryType=Zip

  5. ITAT Mumbai · 07 Mar 2022
    We find the basis of allocation of various expenses has been clearly given by the assessee for each of the segments

    M/S TELEPERFORMANCE GLOBAL SERVICES PVT. LTD. (FORMERLY KNOWN AS ‘INTELENET GLOBAL SERVICES PVT. LTD., MUMBAI AND PRIOR TO THAT KNOWN AS SERCO BPO PVT. LTD) VERSUS THE ASSISTANT COMMISSIONER OF INCOME TAX-12 (2) (2) MUMBAI

    (2022) TaxCorp(LJ) 28529 (ITAT-MUMBAI) · https://taxcorp.in/FileOpenDT.aspx?ID=95950&Category=ITAT&CategoryType=Zip

  6. ITAT Delhi · 07 Mar 2022
    The CIT(A) has rightly upheld the disallowance made by the A.O. in respect of the claim made by the assessee for deduction of annual of mixed use charges paid by the assessee to Municipal Corporation of Delhi, in respect of the property of the Assessee.

    AMAR CHAND GARG VERSUS ACIT, CIRCLE 35 (1) NEW DELHI

    (2022) TaxCorp(LJ) 28528 (ITAT-DELHI) · https://taxcorp.in/FileOpenDT.aspx?ID=95954&Category=ITAT&CategoryType=Zip

  7. ITAT Mumbai · 07 Mar 2022
    Rejection of RPM method adopted by the assessee was incorrect, and learned CIT(A) has rightly reversed the said action.

    DIESEL FASHION INDIA RELIANCE PVT. LTD. VERSUS ASSISTANT COMMISSIONER OF INCOME TAX, 3 (1) (1) MUMBAI, DEPUTY COMMISSIONER OF INCOME TAX, 3 (1) (1) MUMBAI

    (2022) TaxCorp(LJ) 28527 (ITAT-MUMBAI) · https://taxcorp.in/FileOpenDT.aspx?ID=95956&Category=ITAT&CategoryType=Zip

  8. ITAT Bangalore · 07 Mar 2022
    The fact that the debt is outstanding for a long time without any payment cannot be the basis to come to a conclusion that the said debt ceased to exist. We, therefore, confirm the order of the CIT(A).

    DCIT, CIRCLE – 1 (1) (2) , BENGALURU. VERSUS M/S. BPL LTD.

    (2022) TaxCorp(LJ) 28526 (ITAT-BANGALORE) · https://taxcorp.in/FileOpenDT.aspx?ID=95958&Category=ITAT&CategoryType=Zip

  9. ITAT Bangalore · 05 Mar 2022
    Unless funds are borrowed for making deposit to earn interest income, such interest paid on borrowings cannot be allowed as deduction in the computation of income from other sources, which in this case, is interest earned from mutual funds.

    Anirudh Murthy Ranga Vs The Principal Commissioner of Income Tax

    (2022) TaxCorp(LJ) 28525 (ITAT-BANGALORE)

  10. ITAT Mumbai · 05 Mar 2022
    Transponder charges paid to non-residents was not taxable as royalty.

    Viacom 18 Media Private Limited Vs The Asst. Commissioner of Income Tax

    (2022) TaxCorp(LJ) 28524 (ITAT-MUMBAI)

  11. ITAT Delhi · 05 Mar 2022
    Collection of annual mixed use charges would not make any difference in the annual let out value of the property and thus, the same was not allowable as per the proviso to Section 23(1).

    Amar Chand Garg Vs ACIT

    (2022) TaxCorp(LJ) 28523 (ITAT-DELHI) · Section 23(1)

  12. ITAT Chandigarh · 05 Mar 2022
    No tax was deducted on such payments which made the payment suspicious and no independent enquiries have been made to verify wages payable being old one.

    Ashwani Marwah Vs Pr. Commissioner of Income Tax

    (2022) TaxCorp(LJ) 28522 (ITAT-CHANDIGARH)

  13. ITAT Mumbai · 05 Mar 2022
    When an assessment framed by the ld. AO is unsustainable in the eyes of law, the said invalid and illegal order cannot be subject matter of section 263 proceedings.

    Aishwarya Rai Bachchan Vs The Pr. CIT-8

    (2022) TaxCorp(LJ) 28521 (ITAT-MUMBAI)

  14. ITAT Mumbai · 05 Mar 2022
    Rate of tax provided in the tax treaty cannot be enhanced by including surcharge and education cess separately.

    Renaissance Services BV Vs Deputy Director of Income Tax (International Taxation)-2(1)

    (2022) TaxCorp(LJ) 28520 (ITAT-MUMBAI)

  15. Bombay High Court · 05 Mar 2022
    Change in opinion cannot constitute reason to believe.

    Mangalore Refinery and Petrochemicals Limited Vs The Deputy Commissioner of Income Tax

    (2022) TaxCorp(LJ) 28519 (HC-BOMBAY)

  16. Bombay High Court · 05 Mar 2022
    The assessment order is required to be quashed and set aside.

    Hactom Agro Pvt Ltd Vs National E Asesment Centre & ors

    (2022) TaxCorp(LJ) 28518 (HC-BOMBAY)

  17. ITAT Bangalore · 05 Mar 2022
    Unless the write off takes place at the time of finalisation of account and reflected in the books of account, it cannot be treated as write of at all.

    Avijit Dewanjee Vs The Deputy Commissioner of Income Tax

    (2022) TaxCorp(LJ) 28517 (ITAT-BANGALORE)

  18. ITAT Surat · 05 Mar 2022
    No proper books of account were maintained till the date of survey. The entire exercise of preparing the alleged audited books was nothing but an afterthought of the Assessee.

    Bajarang Developers Vs The Assistant Commissioner of Income Tax

    (2022) TaxCorp(LJ) 28516 (ITAT-SURAT)

  19. ITAT Bangalore · 05 Mar 2022
    The payment has been made by the assessee under protest. Therefore, the amount is definitely a disputed liability and cannot be said that the liability has crystallized/accrued to the assessee during the relevant assessment year.

    M/S I.G. PETROCHEMICALS LIMITED VERSUS THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE (3) (1) (1) BENGALURU

    (2022) TaxCorp(LJ) 28514 (ITAT-BANGALORE) · https://taxcorp.in/FileOpenDT.aspx?ID=95919&Category=ITAT&CategoryType=Zip

  20. ITAT Bangalore · 05 Mar 2022
    The AO is not right in adding back the provisions made by the assessee towards gratuity, leave encashment and bonus for computation of book profits u/s. 115JB on the ground that they are unascertained liability.

    JEANS KNIT PVT. LTD. VERSUS THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-4 (1) (1) BENGALURU

    (2022) TaxCorp(LJ) 28513 (ITAT-BANGALORE) · https://taxcorp.in/FileOpenDT.aspx?ID=95920&Category=ITAT&CategoryType=Zip

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