The Karnataka High Court held that the transfer of intangible assets for a valuable consideration by way of allotment of shares is entitled for depreciation. The assessee, M/s Padmini Products is a Private Limited Company...
The Income Tax Appellate Tribunal (ITAT), Bangalore Bench while remitting the matter back to the CIT(A) ruled that the CIT(A) ought to analyse nature of service undertaken by assessee and taxation of fees for technical...
The Income Tax Appellate Tribunal (ITAT), Mumbai Bench deleted the addition on account of alleged royalty taxable under section 9 (l)(vi) of the Income Tax Act, 1961 read with Article 12(3) of India Switzerland Double...
The Delhi bench of Income Tax Appellate Tribunal (ITAT) has held that indirect transfer of Indian assets will not attract Long Term Capital Gains Tax (LTCG). The appellant company, Augustus Capital PTE Ltd. is in...
The Income Tax Appellate Tribunal (ITAT), Bangalore Bench held that the Assessing Officer (AO) is not empowered to reject selection and valuation methods adopted by taxpayers. The assessee company, M/s. GSE Commerce Private Ltd. operates...
The Income Tax Appellate Tribunal (ITAT), Delhi Bench held that the leasehold rights can not be computed as capital gains in respect of transactions in land or building under Section 50C of the Income Tax...
The Income Tax Appellate Tribunal (ITAT), New Delhi Bench held that Mitsui India is not a Dependent Agent PE In India (DAPE) under India-Japan Tax Treaty. The assessee, M/s. Mitsui & Co. Ltd. (MIPL) is...
The Income Tax Appellate Tribunal (ITAT) directed the Assessing Officer (AO) to delete the disallowance of salary paid overseas to expatriates of the MUFG Bank working in India by Head Office. The assessee, MUFG Bank...
The Income Tax Appellate Tribunal (ITAT), New Delhi Bench held that the consideration received on Bandwidth services provided outside India is not taxable as ‘Royalty’ under India-Singapore Double Taxation Avoidance Agreement (DTAA). The assessee company,...
The Income Tax Appellate Tribunal (ITAT), Bangalore Bench held that the usage of fund cannot be the reason to impose tax liability. The assessee filed his return of income for the assessment year returning an...
The Income Tax Appellate Tribunal (ITAT), New Delhi held that the revenue derived from the distribution of products cannot be taxed as ‘royalty’ as business income as it is already offered under Mutual Agreement Procedure...
The Income Tax Appellate Tribunal (ITAT), Delhi Bench held that tax rates specified in Double Taxation Avoidance Agreement (DTAA) in respect of dividend must prevail over Dividend Distribution Tax (DDT). The appellant, Giesecke & Devrient...
The Income Tax Appellate Tribunal (ITAT), New Delhi Bench while granting relief to Nokia India held that no disallowance of non-deduction of TDS for expenses incurred on trade offers provided to distributors. The Assessee, Nokia...
The Income Tax Appellate Tribunal (ITAT), New Delhi Bench imposed the penalty for failure to maintain Transfer Pricing Documents under and Section 271AA. The assessee, Convergys Customer Management Group Inc. is a non-resident company incorporated...
The Karnataka High Court, while ruling in the favour of the assessee, Intel Capital (Cayman) Corporation held that the ITAT rightly computed the capital gains by adopting the rate of acquisition at Rs.200. The assessee,...
The Income Tax Appellate Tribunal (ITAT), Delhi Bench held that the Cost allocation of international freight logistic support services and reimbursement of Global Account Management (GAM) expenses can not be treated as Technical Services or...
The Income Tax Appellate Tribunal (ITAT), Mumbai Bench held that TDS cannot be deducted on the rent if the accommodation services were taken on a casual basis. The assessee, Dadiba kali Pundole Esplanade House is...
The Income Tax Appellate Tribunal (ITAT), Mumbai Bench held that the Income received for sale of specialized software and maintenance and support services is not “Royalty” as per India-Finland Tax Treaty. The assessee, Trimble Solutions...
The Karnataka High Court while dismissing the plea of the revenue held that the revenue is liable to pay interest on the amount of interest on refund. The assessee, Syndicate Bank is a Nationalized Commercial...
The Income Tax Appellate Tribunal (ITAT), Mumbai Bench held that roaming charges paid by Reliance Communications are not in the nature of ‘fee for technical services’, tax deducted at source (TDS) not liable to be...
The Income Tax Appellate Tribunal (ITAT), Mumbai Bench held that PCIT rightly directed the Bank of India’s case to the Transfer Pricing Officer (TPO) under section 92CA for determination of arm’s length price (ALP) in...
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