75% Gross Profit Earned from Indian Operations: Delhi HC upholds Direction of the AO to Adopt Attribution Rate of Revenue [Read Order]
The Delhi High Court upheld the direction of the Assessing Officer ( AO ) to adopt the attribution rate of revenue as 75% gross profit earned from...
![Disallowance u/s 14 A of Income Tax Act not warranted in Absence of Borrowed Fund in Books of Accounts: Delhi HC [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/12/Income-Tax-Act-Absence-of-Borrowed-Fund-Borrowed-Fund-Books-of-Accounts-Delhi-High-Court-TAXSCAN.jpg "Disallowance u/s 14 A of Income Tax Act not warranted in Absence of Borrowed Fund in Books of Accounts: Delhi HC [Read Order]")
![Benefit of Article 8 of India-Singapore DTAA shall be allowed when Vessel Handling Charges were allowed to Tax by Indian Entity: ITAT [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/11/Benefit-India-Singapore-DTAA-Vessel-Handling-Charges-Tax-Indian-Entity-ITAT-TAXSCAN.jpg "Benefit of Article 8 of India-Singapore DTAA shall be allowed when Vessel Handling Charges were allowed to Tax by Indian Entity: ITAT [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]](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]")
Absence of 'make available' clause, services rendered not FTS under India-Netherland DTAA: ITAT grants Relief to Shell Global Solutions Intl [Read Order]
The Ahmedabad Bench of Income Tax Appellate Tribunal (ITAT) held that the condition of “make available” has not been satisfied in the instant set of facts and hence, the services do not qualify as...
AMP Expenditure not an International Transaction: ITAT deletes Addition against Mondelez India Foods towards Transfer Pricing Adjustment on Account of AMP Expenditure [Read Order]
The Mumbai Bench of Income Tax Appellate Tribunal (ITAT) has deleted the addition against Mondelez India Foods towards the transfer pricing adjustment on account of Advertisement, Marketing and...
![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]
The Delhi bench of the Income Tax Appellate Tribunal (ITAT) held that the benefit of Arm's Length Price (ALP) falls within the tolerance band of +/- of 5% as per Section 92C(2) of the Income Tax Act,...
![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]
The Income Tax Appellate Tribunal (ITAT ) Kolkata held that Income earned from providing It services to Indian Customers is taxable in India because the service is used in india. Assessee,...
![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]")