145 orders · Page 2 of 3
The Tribunal held that the additions on account of unexplained FDRs could not be made in the hands of the larger HUF due to partition, nor in the hands of the individual, but should be apportioned among smaller HUFs. Credit for agricultural and business income should be given.
The Tribunal held that the additions on account of unexplained FDRs could not be made in the hands of the larger HUF due to partition, nor in the hands of the individual, but should be apportioned among smaller HUFs. Credit for agricultural and business income should be given.
The Tribunal held that the additions on account of unexplained FDRs could not be made in the hands of the larger HUF due to partition, nor in the hands of the individual, but should be apportioned among smaller HUFs. Credit for agricultural and business income should be given.
The Tribunal held that the additions on account of unexplained FDRs could not be made in the hands of the larger HUF due to partition, nor in the hands of the individual, but should be apportioned among smaller HUFs. Credit for agricultural and business income should be given.
The Tribunal held that the additions on account of unexplained FDRs could not be made in the hands of the larger HUF due to partition, nor in the hands of the individual, but should be apportioned among smaller HUFs. Credit for agricultural and business income should be given.
The Tribunal held that the additions on account of unexplained FDRs could not be made in the hands of the larger HUF due to partition, nor in the hands of the individual, but should be apportioned among smaller HUFs. Credit for agricultural and business income should be given.
The Tribunal held that the additions on account of unexplained FDRs could not be made in the hands of the larger HUF due to partition, nor in the hands of the individual, but should be apportioned among smaller HUFs. Credit for agricultural and business income should be given.
The Tribunal held that the additions on account of unexplained FDRs could not be made in the hands of the larger HUF due to partition, nor in the hands of the individual, but should be apportioned among smaller HUFs. Credit for agricultural and business income should be given.
The Tribunal held that the additions on account of unexplained FDRs could not be made in the hands of the larger HUF due to partition, nor in the hands of the individual, but should be apportioned among smaller HUFs. Credit for agricultural and business income should be given.
The Tribunal held that the additions on account of unexplained FDRs could not be made in the hands of the larger HUF due to partition, nor in the hands of the individual, but should be apportioned among smaller HUFs. Credit for agricultural and business income should be given.
The Tribunal held that the additions on account of unexplained FDRs could not be made in the hands of the larger HUF due to partition, nor in the hands of the individual, but should be apportioned among smaller HUFs. Credit for agricultural and business income should be given.
The Tribunal held that the additions on account of unexplained FDRs could not be made in the hands of the larger HUF due to partition, nor in the hands of the individual, but should be apportioned among smaller HUFs. Credit for agricultural and business income should be given.
The Tribunal held that the additions on account of unexplained FDRs could not be made in the hands of the larger HUF due to partition, nor in the hands of the individual, but should be apportioned among smaller HUFs. Credit for agricultural and business income should be given.
The Tribunal held that the additions on account of unexplained FDRs could not be made in the hands of the larger HUF due to partition, nor in the hands of the individual, but should be apportioned among smaller HUFs. Credit for agricultural and business income should be given.
The Tribunal held that the additions on account of unexplained FDRs could not be made in the hands of the larger HUF due to partition, nor in the hands of the individual, but should be apportioned among smaller HUFs. Credit for agricultural and business income should be given.
The Tribunal held that the additions on account of unexplained FDRs could not be made in the hands of the larger HUF due to partition, nor in the hands of the individual, but should be apportioned among smaller HUFs. Credit for agricultural and business income should be given.
The Tribunal held that the additions on account of unexplained FDRs could not be made in the hands of the larger HUF due to partition, nor in the hands of the individual, but should be apportioned among smaller HUFs. Credit for agricultural and business income should be given.
The Tribunal held that the additions on account of unexplained FDRs could not be made in the hands of the larger HUF due to partition, nor in the hands of the individual, but should be apportioned among smaller HUFs. Credit for agricultural and business income should be given.
The Tribunal held that the additions on account of unexplained FDRs could not be made in the hands of the larger HUF due to partition, nor in the hands of the individual, but should be apportioned among smaller HUFs. Credit for agricultural and business income should be given.
The Tribunal held that the additions on account of unexplained FDRs could not be made in the hands of the larger HUF due to partition, nor in the hands of the individual, but should be apportioned among smaller HUFs. Credit for agricultural and business income should be given.
The Tribunal held that the additions on account of unexplained FDRs could not be made in the hands of the larger HUF due to partition, nor in the hands of the individual, but should be apportioned among smaller HUFs. Credit for agricultural and business income should be given.
The Tribunal held that the additions on account of unexplained FDRs could not be made in the hands of the larger HUF due to partition, nor in the hands of the individual, but should be apportioned among smaller HUFs. Credit for agricultural and business income should be given.
The Tribunal held that the larger HUF was indeed partitioned and thus no assessment could be made against it. Additions made in the hands of the larger HUF were deleted, but the matter was remanded for recomputation of investments in smaller HUFs.
The Tribunal held that the additions made on account of unexplained FDR investments could not be made in the hands of the larger HUF due to partition, nor in the hands of the individual, but should be apportioned among smaller HUFs. The matter was restored to the AO for recomputation.
The Tribunal held that the additions on account of unexplained FDRs could not be made in the hands of the larger HUF due to partition, nor in the hands of the individual, but should be apportioned among smaller HUFs. Credit for agricultural and business income should be given.
The Tribunal held that the lower authorities' estimation of revenue for deduction was arbitrary and without basis. The matter was remanded to the CIT(A) to obtain records from NHAI to determine the correct basis for annuity fixation and the eligible deduction for widening and strengthening the road.
The Tribunal held that non-payment of tax on returned income before filing an appeal is a curable defect, not a voiding condition. Since the taxes were paid, the appeal should be admitted and decided on merits.
The Tribunal held that new claims can be made at any stage of appellate proceedings, and the Supreme Court's decision in Goetze (India) Ltd. is confined to the powers of the assessing officer. The appellate authorities have the jurisdiction to entertain new claims.
The Tribunal, following the Supreme Court's decision in CIT v. HCL Technologies Ltd., held that expenses incurred in foreign currency should be reduced from both export turnover and total turnover for the purpose of computing deduction under Section 10A.
The Tribunal observed that the assessee was not interested in prosecuting its case. Therefore, the appeal was dismissed for non-prosecution.
The Tribunal held that payments made to IBM Philippines were not taxable in India as they constituted business income falling under Article 7 of the DTAA, and IBM Philippines had no Permanent Establishment in India. It also held that the higher TDS rate under Section 206AA would not override beneficial provisions of DTAAs.
The Tribunal held that payments made to IBM Philippines were not taxable in India as they constituted business income falling under Article 7 of the DTAA, and IBM Philippines had no Permanent Establishment in India. It also held that the higher TDS rate under Section 206AA would not override beneficial provisions of DTAAs.
The Tribunal dismissed the appeals filed by the Revenue, citing CBDT Circular No. 3/2018 which sets a monetary limit of Rs. 20 lakhs for filing appeals before the ITAT. The Revenue's representative admitted the tax effect was below this limit.
The Tribunal held that payments made to IBM Philippines were not taxable in India as they constituted business income falling under Article 7 of the DTAA, and IBM Philippines had no Permanent Establishment in India. It also held that the higher TDS rate under Section 206AA would not override beneficial provisions of DTAAs.
The Tribunal held that the validity of the assumption of jurisdiction under Section 147 of the Income Tax Act could not be upheld. Consequently, the impugned assessment orders were quashed as bad in law.
The Tribunal held that the validity of the assumption of jurisdiction under Section 147 of the Income Tax Act could not be upheld. Consequently, the impugned assessment orders were quashed as bad in law.
The Tribunal held that the validity of the assumption of jurisdiction under Section 147 of the Income Tax Act could not be upheld. Consequently, the impugned assessment orders were quashed as bad in law.
The Tribunal held that the CIT(A) was correct in deleting the addition by following the jurisdictional High Court's decisions. The High Court had held that employee's contribution to PF/ESI, if paid before the due date for filing the return of income, is eligible for deduction.
The Tribunal held that payments made to IBM Philippines were not taxable in India as they constituted business income falling under Article 7 of the DTAA, and IBM Philippines had no Permanent Establishment in India. It also held that the higher TDS rate under Section 206AA would not override beneficial provisions of DTAAs.
The Tribunal held that payments made to IBM Philippines were not taxable in India as they constituted business income falling under Article 7 of the DTAA, and IBM Philippines had no Permanent Establishment in India. It also held that the higher TDS rate under Section 206AA would not override beneficial provisions of DTAAs.
The Tribunal held that payments made to IBM Philippines were not taxable in India as they constituted business income falling under Article 7 of the DTAA, and IBM Philippines had no Permanent Establishment in India. It also held that the higher TDS rate under Section 206AA would not override beneficial provisions of DTAAs.
The Tribunal held that as per CBDT Circular No. 3/2018, appeals with a tax effect below Rs. 20 Lakhs are not maintainable. Therefore, the revenue's appeal was dismissed on this ground.
The Tribunal held that Section 14A cannot be invoked in the absence of any exempt income, aligning with the settled position of law. Therefore, the disallowance made by the AO was not sustainable.
The Tribunal held that the issue of carrying forward excess application of income as losses for charitable trusts has been decided in favour of the assessee by the Hon'ble Supreme Court. Therefore, the Revenue's appeals lacked merit.
The Tribunal held that the CIT(A) did not consider the written submissions and supporting documents filed by the assessee. Therefore, the issue of disallowance under Section 14A was set aside and remanded for fresh consideration by the CIT(A).
The Tribunal held that the payment for software was in the nature of royalty, even if termed as reimbursement. Therefore, tax deduction at source was mandatory.
The Tribunal held that the payment for software was in the nature of royalty, even if termed as reimbursement. Therefore, tax deduction at source was mandatory under Section 195.
The Tribunal held that the issue of carrying forward excess application of income as losses for charitable trusts has been decided in favour of the assessee by the Hon'ble Supreme Court. Therefore, the Revenue's appeals lacked merit.
The Tribunal directed the exclusion of 'e-Zest Solutions Ltd.' from the comparables list, following a co-ordinate bench's decision that it provided product development and KPO services, not comparable to software development. The Tribunal also upheld the disallowance of software expenses for non-deduction of TDS.