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316 orders · Page 1 of 7
The Tribunal allowed the appeals, agreeing with the assessee's contention that the payments were not taxable as 'Fee for Technical Services' in India. The Tribunal also concurred with the deletion of additions related to BPO services in certain cases.
The Tribunal allowed the appeals, agreeing with the assessee's contention that the payments were not taxable as 'Fee for Technical Services' in India. The Tribunal also concurred with the deletion of additions related to BPO services in certain cases.
The Tribunal allowed the appeals, agreeing with the assessee's contention that the payments were not taxable as 'Fee for Technical Services' in India. The Tribunal also concurred with the deletion of additions related to BPO services in certain cases.
The Tribunal allowed the appeals, agreeing with the assessee's contention that the payments were not taxable as 'Fee for Technical Services' in India. The Tribunal also concurred with the deletion of additions related to BPO services in certain cases.
The Tribunal allowed the appeals, agreeing with the assessee's contention that the payments were not taxable as 'Fee for Technical Services' in India. The Tribunal also concurred with the deletion of additions related to BPO services in certain cases.
The Tribunal allowed the appeals, agreeing with the assessee's contention that the payments were not taxable as 'Fee for Technical Services' in India. The Tribunal also concurred with the deletion of additions related to BPO services in certain cases.
The Tribunal allowed the appeals, agreeing with the assessee's contention that the payments were not taxable as 'Fee for Technical Services' in India. The Tribunal also concurred with the deletion of additions related to BPO services in certain cases.
The Tribunal allowed the appeals, agreeing with the assessee's contention that the payments were not taxable as 'Fee for Technical Services' in India. The Tribunal also concurred with the deletion of additions related to BPO services in certain cases.
The Tribunal allowed the appeals, agreeing with the assessee's contention that the payments were not taxable as 'Fee for Technical Services' in India. The Tribunal also concurred with the deletion of additions related to BPO services in certain cases.
The Tribunal allowed the appeals, agreeing with the assessee's contention that the payments were not taxable as 'Fee for Technical Services' in India. The Tribunal also concurred with the deletion of additions related to BPO services in certain cases.
The Tribunal allowed the appeals, agreeing with the assessee's contention that the payments were not taxable as 'Fee for Technical Services' in India. The Tribunal also concurred with the deletion of additions related to BPO services in certain cases.
The Tribunal allowed the appeals, agreeing with the assessee's contention that the payments were not taxable as 'Fee for Technical Services' in India. The Tribunal also concurred with the deletion of additions related to BPO services in certain cases.
The Tribunal allowed the appeals, agreeing with the assessee's contention that the payments were not taxable as 'Fee for Technical Services' in India. The Tribunal also concurred with the deletion of additions related to BPO services in certain cases.
The Tribunal allowed the appeals, agreeing with the assessee's contention that the payments were not taxable as 'Fee for Technical Services' in India. The Tribunal also concurred with the deletion of additions related to BPO services in certain cases.
The Tribunal allowed the appeals, agreeing with the assessee's contention that the payments were not taxable as 'Fee for Technical Services' in India. The Tribunal also concurred with the deletion of additions related to BPO services in certain cases.
The Tribunal allowed the appeals, agreeing with the assessee's contention that the payments were not taxable as 'Fee for Technical Services' in India. The Tribunal also concurred with the deletion of additions related to BPO services in certain cases.
The Tribunal allowed the appeals, agreeing with the assessee's contention that the payments were not taxable as 'Fee for Technical Services' in India. The Tribunal also concurred with the deletion of additions related to BPO services in certain cases.
The Tribunal allowed the appeals, agreeing with the assessee's contention that the payments were not taxable as 'Fee for Technical Services' in India. The Tribunal also concurred with the deletion of additions related to BPO services in certain cases.
The Tribunal allowed the appeals, agreeing with the assessee's contention that the payments were not taxable as 'Fee for Technical Services' in India. The Tribunal also concurred with the deletion of additions related to BPO services in certain cases.
The Tribunal allowed all appeals, concurring with the submissions that the receipts from BPO services should not be taxed in India, following a previous decision. The appeals were allowed with consequences to follow as determined in favor of the appellants.
The Tribunal allowed the appeals, agreeing with the assessee's contention that the payments were not taxable as 'Fee for Technical Services' in India. The Tribunal also concurred with the deletion of additions related to BPO services in certain cases.
The Tribunal allowed the appeals, agreeing with the assessee's contention that the payments were not taxable as 'Fee for Technical Services' in India. The Tribunal also concurred with the deletion of additions related to BPO services in certain cases.
The Tribunal allowed the appeals, agreeing with the assessee's contention that the payments were not taxable as 'Fee for Technical Services' in India. The Tribunal also concurred with the deletion of additions related to BPO services in certain cases.
The Tribunal allowed the Miscellaneous Applications, recalling the ex-parte dismissal for a fresh hearing. Consequently, the matter regarding the ESI/PF contributions is remanded to the Assessing Officer. The AO is directed to examine the payment dates and allow the deduction in accordance with the Supreme Court's decision in Checkmate Services Vs. CIT. The appeals are allowed for statistical purposes.
The Tribunal observed that the CIT(A) orders lacked details on notice service. It was held that the assessee deserved an opportunity for a merit-based hearing. Therefore, the appeals were allowed for statistical purposes and remanded to the CIT(A) for fresh adjudication after granting a proper hearing.
The Tribunal allowed the appeals, agreeing with the assessee's contention that the payments were not taxable as 'Fee for Technical Services' in India. The Tribunal also concurred with the deletion of additions related to BPO services in certain cases.
The Tribunal allowed the appeals, agreeing with the assessee's contention that the payments were not taxable as 'Fee for Technical Services' in India. The Tribunal also concurred with the deletion of additions related to BPO services in certain cases.
The Tribunal found an inherent error in the assessment proceedings as the addition was based on a wrong fact about the real identity of the bank accountholder. It restored the matter to the AO for fresh adjudication on merits, providing the assessee an opportunity of hearing.
The Tribunal allowed the appeals, agreeing with the assessee's contention that the payments were not taxable as 'Fee for Technical Services' in India. The Tribunal also concurred with the deletion of additions related to BPO services in certain cases.
The Tribunal allowed the appeals, agreeing with the assessee's contention that the payments were not taxable as 'Fee for Technical Services' in India. The Tribunal also concurred with the deletion of additions related to BPO services in certain cases.
The Tribunal observed that the CIT(A) orders lacked details on notice service. It was held that the assessee deserved an opportunity for a merit-based hearing. Therefore, the appeals were allowed for statistical purposes and remanded to the CIT(A) for fresh adjudication after granting a proper hearing.
The Tribunal allowed the appeals, agreeing with the assessee's contention that the payments were not taxable as 'Fee for Technical Services' in India. The Tribunal also concurred with the deletion of additions related to BPO services in certain cases.
The Tribunal noted that the tax effect in the Revenue's appeal was indeed below Rs. 50 lakhs. Citing CBDT Circular No. 17/2019 and its clarification, which makes the Rs. 50 lakh monetary limit for filing appeals applicable to pending cases, the Tribunal held that the Revenue's appeal was not maintainable.
The Tribunal allowed the appeals, agreeing with the assessee's contention that the payments were not taxable as 'Fee for Technical Services' in India. The Tribunal also concurred with the deletion of additions related to BPO services in certain cases.
The Tribunal allowed the appeals, agreeing with the assessee's contention that the payments were not taxable as 'Fee for Technical Services' in India. The Tribunal also concurred with the deletion of additions related to BPO services in certain cases.
The Tribunal allowed the appeals, agreeing with the assessee's contention that the payments were not taxable as 'Fee for Technical Services' in India. The Tribunal also concurred with the deletion of additions related to BPO services in certain cases.
The Tribunal allowed the appeals, agreeing with the assessee's contention that the payments were not taxable as 'Fee for Technical Services' in India. The Tribunal also concurred with the deletion of additions related to BPO services in certain cases.
The Tribunal allowed the appeals, agreeing with the assessee's contention that the payments were not taxable as 'Fee for Technical Services' in India. The Tribunal also concurred with the deletion of additions related to BPO services in certain cases.
The Tribunal allowed the appeals, agreeing with the assessee's contention that the payments were not taxable as 'Fee for Technical Services' in India. The Tribunal also concurred with the deletion of additions related to BPO services in certain cases.
The Tribunal held that the generation of a challan signifies the initiation and intention of deposit. It found that the assessee's explanation of an 11-hour delay due to a technical glitch was credible and not disbelieved by the tax authorities. The Tribunal, acting as a quasi-judicial authority, deemed it appropriate to accept the plea, as it was not against facts or law and arose from natural events.
The Tribunal concurred with the lower authorities, noting that the assessee failed to provide any evidence to establish the genuineness of the transactions or the identity and creditworthiness of the investing entities. Consequently, the addition was upheld, as the grounds raised by the assessee lacked substance.
The Tribunal allowed the appeals, agreeing with the assessee's contention that the payments were not taxable as 'Fee for Technical Services' in India. The Tribunal also concurred with the deletion of additions related to BPO services in certain cases.
The Tribunal allowed the appeals, agreeing with the assessee's contention that the payments were not taxable as 'Fee for Technical Services' in India. The Tribunal also concurred with the deletion of additions related to BPO services in certain cases.
The Tribunal allowed the appeals, agreeing with the assessee's contention that the payments were not taxable as 'Fee for Technical Services' in India. The Tribunal also concurred with the deletion of additions related to BPO services in certain cases.
The Tribunal allowed the appeals, agreeing with the assessee's contention that the payments were not taxable as 'Fee for Technical Services' in India. The Tribunal also concurred with the deletion of additions related to BPO services in certain cases.
The Tribunal allowed the appeals, agreeing with the assessee's contention that the payments were not taxable as 'Fee for Technical Services' in India. The Tribunal also concurred with the deletion of additions related to BPO services in certain cases.
The Tribunal observed that it is common for past banking channel receipts to be recorded as cash in sale deeds. It held that discrediting the assessee's defense solely based on the sale deed's recital was not justified, especially when a significant portion was demonstrably received through banking channels. Therefore, burdening the assessee with penalty under Section 271D was deemed not justified.
The ITAT held that no addition was called for regarding the demonetization cash deposit, as the assessee maintained sufficient stock, books were accepted by the AO, and cash sales were commensurate without abnormal increase. Regarding unsecured loans, the ITAT, after examining the detailed circular transactions through Ghaziabad Nursing Home, found that the source of amounts was duly explained and thus held that no addition was required on this account. Consequently, both primary additions challenged by the assessee were deleted.
The Tribunal allowed the appeals, agreeing with the assessee's contention that the payments were not taxable as 'Fee for Technical Services' in India. The Tribunal also concurred with the deletion of additions related to BPO services in certain cases.
The Tribunal allowed the appeals, agreeing with the assessee's contention that the payments were not taxable as 'Fee for Technical Services' in India. The Tribunal also concurred with the deletion of additions related to BPO services in certain cases.