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“Section 197(9)”
Section References (mined)Section 197Section 197(9)2 judgments
The decision most relied on for Section 197(9) is Additional Director of Income Tax (IT) v. Mark & Spencer Reliance India (P) Ltd. (38 Taxmann.com 190), cited in 21 judgments on BharatTax.
Leading authorities on Section 197(9)
Additional Director of Income Tax (IT) v. Mark & Spencer Reliance India (P) Ltd.
38 Taxmann.com 190 · 2013 · Reported
21
citing judgments
Part reimbursement of expenses does not constitute income if the services rendered are under the direct control and supervision of the recipient.
DCIT v. KPMG
81 Taxmann.com 118 · 2017 · ITAT
20
citing judgments
The principle of mutuality applies when there is a complete identity between contributors and participators, and their actions are in furtherance of the association's mandate, with no element of profit for the contributors.
Trib.) (para 7), Sonakshi Sinha v. CIT (Appeals)
197 ITD 263 · 2022 · ITAT
15
citing judgments
The time limit for filing Form 67 to claim foreign tax credit is directory, not mandatory. If no negative consequences are contemplated for non-adherence, the provision is considered directory.
