![Penalty u/s 271 (1)(c) of Income Tax Act cannot be invoked in Absence of Material Establishing Concealing of Income: Gujarat HC [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/11/Penalty-Income-Tax-Act-Absence-Material-Establishing-Concealing-Income-Gujarat-HC-TAXSCAN.jpg "Penalty u/s 271 (1)(c) of Income Tax Act cannot be invoked in Absence of Material Establishing Concealing of Income: Gujarat HC [Read Order]")
Penalty u/s 271 (1)(c) of Income Tax Act cannot be invoked in Absence of Material Establishing Concealing of Income: Gujarat HC [Read Order]
In a significant case, the Gujarat High Court has held that penalty under section 271 (1)(c) of the Income Tax Act, 1961 cannot be invoked in the...
![AMP Expenditure not an International Transaction: ITAT deletes Addition against Mondelez India Foods towards Transfer Pricing Adjustment on Account of AMP Expenditure [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/09/AMP-Expenditure-International-Transaction-ITAT-deletes-Addition-ITAT-Addition-Mondelez-India-Foods-taxscan-1.jpg "AMP Expenditure not an International Transaction: ITAT deletes Addition against Mondelez India Foods towards Transfer Pricing Adjustment on Account of AMP Expenditure [Read Order]")
![Benefit of ALP falls within Tolerance Band of +/- of 5% as per Section 92C(2) of Income Tax Act: ITAT [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/09/Arms-Length-Price-Benefit-ALP-falls-Tolerance-Band-Income-Tax-Act-ITAT-taxscan.jpg "Benefit of ALP falls within Tolerance Band of +/- of 5% as per Section 92C(2) of Income Tax Act: ITAT [Read Order]")
![Income earned from providing IT services to Indian customers is taxable in India due to use of service in India: ITAT [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/09/Income-earned-from-providing-IT-services-to-Indian-customers-is-taxable-India-due-service-in-India-ITAT-TAXSCAN.jpg "Income earned from providing IT services to Indian customers is taxable in India due to use of service in India: ITAT [Read Order]")
Interest amount paid by Indian branch to Foreign Head Office is not taxable in India under India France DTAA: ITAT [Read Order]
The Income Tax Appellate Tribunal (ITAT) Mumbai bench held that the interest amount paid by the Indian Branch to Foreign Head office was not taxable in India under India France Double Taxation...
![Interest amount paid by Indian branch to Foreign Head Office is not taxable in India under India France DTAA: ITAT [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/09/Interest-amount-paid-by-Indian-branch-to-Foreign-Head-Office-taxable-in-India-under-India-France-DTAA-ITAT-TAXSCAN.jpg "Interest amount paid by Indian branch to Foreign Head Office is not taxable in India under India France DTAA: ITAT [Read Order]")
Rate of tax applicable to Domestic Banking Companies are not Same as Foreign Banking Company: ITAT [Read Order]
The Income Tax Appellate Tribunal (ITAT) Mumbai bench held that the rate of tax applicable to domestic banking companies is not the same as foreign banking companies. Tax levied at a higher rate...
![Rate of tax applicable to Domestic Banking Companies are not Same as Foreign Banking Company: ITAT [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/09/Rate-of-tax-applicable-to-Domestic-Banking-companies-Foreign-Banking-Company-ITAT-TAXSCAN.jpg "Rate of tax applicable to Domestic Banking Companies are not Same as Foreign Banking Company: ITAT [Read Order]")
Income from sub licensing software for healthcare business in India Shall not be taxed as Business Income under India – USA DTAA due to absence of PE: ITAT [Read Order]
The Income Tax Appellate Tribunal (ITAT) Delhi bench held that the Income from sub licensing software for the healthcare business in India should not be taxed under Business Income due to...
![Income from sub licensing software for healthcare business in India Shall not be taxed as Business Income under India – USA DTAA due to absence of PE: ITAT [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/09/Income-sub-licensing-software-healthcare-business-India-Business-Income-India-USA-DTAA-PE-ITAT-TAXSCAN.jpg "Income from sub licensing software for healthcare business in India Shall not be taxed as Business Income under India – USA DTAA due to absence of PE: ITAT [Read Order]")
Service Fees for Providing Supporting Services Taxable as FTS u/s 9(1)(vii) of Income Tax Act and Article 12(4) of India-USA DTAA: ITAT [Read Order]
The Mumbai Bench of Income Tax Appellate Tribunal (ITAT) held that the cost reimbursement of received by the assessee towards providing support services is taxable as fees for technical services both...
![Service Fees for Providing Supporting Services Taxable as FTS u/s 9(1)(vii) of Income Tax Act and Article 12(4) of India-USA DTAA: ITAT [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/08/Service-Fees-Supporting-Services-Taxable-FTS-Income-Tax-Act-Article-India-USA-DTAA-ITAT-TAXSCAN.jpg "Service Fees for Providing Supporting Services Taxable as FTS u/s 9(1)(vii) of Income Tax Act and Article 12(4) of India-USA DTAA: ITAT [Read Order]")
Receipts from Disaster Recovery Up-Linking Services are not Royalty: ITAT deletes Addition [Read Order]
The Income Tax Appellate Tribunal (ITAT) Delhi Bench held that receipts from disaster recovery up-linking services are not Royalty. Therefore the bench deleted the addition made by the assessing...
![Receipts from Disaster Recovery Up-Linking Services are not Royalty: ITAT deletes Addition [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/08/ITAT-deletes-Addition-Receipts-Disaster-Recovery-Up-Linking-Services-Disaster-Recovery-Receipts-from-Disaster-Recovery-Up-Linking-Services-are-not-Royalty-ITAT-Taxscan.jpg "Receipts from Disaster Recovery Up-Linking Services are not Royalty: ITAT deletes Addition [Read Order]")
![Retaining Disallowance without Following Directions of DRP: ITAT directs Re adjudication [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/08/Retaining-Disallowance-Following-Directions-of-DRP-ITAT-directs-Readjudication-TAXSCAN.jpg "Retaining Disallowance without Following Directions of DRP: ITAT directs Re adjudication [Read Order]")
![ITAT deletes TP adjustment made towards rendering of GIS services by AE for Advertising Business [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/06/ITAT-TP-adjustment-GIS-services-AE-advertising-business-income-tax-income-tax-taxscans.jpg "ITAT deletes TP adjustment made towards rendering of GIS services by AE for Advertising Business [Read Order]")