1502 15 july_2016
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The document provides a summary of recent legal landmarks related to taxation in India. It includes 6 rulings from various authorities like Delhi ITAT, Rajasthan ITAT, Bombay HC, Supreme Court of India, Kolkata ITAT, and Mumbai ITAT. Each ruling summarizes the section of law, ratio or key point of the ruling, citation details, and name of the assessed party. The rulings covered topics like deductions, assessments, income from foreign gifts, transfer pricing, and accrual of income.
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This document provides a summary of recent legal landmarks from various courts:
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3. The Delhi High Court stated that the Berry Ratio can be used as a comparable uncontrolled price for applying the TNMM transfer pricing method but only in limited circumstances.
854 11 sep_2014
This document provides a summary of recent legal landmarks related to taxation. It lists 6 cases from various High Courts and Tax Appellate Tribunals across India. For each case, it provides the authority, relevant section/rules of the Income Tax Act, a brief ratio or principle from the case, and case name and citation. The cases addressed a range of tax issues like what expenses need to be added to income, application of transfer pricing methods, comparable filters for transfer pricing adjustments, interest rates on loans to foreign affiliates, and questioning of payments to related parties.
1513 28 july_2016
This document provides a summary of recent legal landmarks from various tax authorities and courts in India. It lists 6 rulings covering topics like transfer pricing comparables, deductibility of interest expenses, applicability of appeal filing limits. Each ruling cites the relevant section/rule of tax law, provides a brief ratio or reasoning from the case, and identifies the case name and assessee involved. The rulings relate to matters like what constitutes a pass through cost, whether certain industries can be comparable for transfer pricing, interest expenses being business expenditures and applicability of appeal filing limits.
1510 25 july_2016
This document provides a summary of recent legal landmarks across various authorities in India:
1. The Delhi ITAT held that if a transfer pricing method was applied in good faith, penalties under section 271(1)(c) will not be attracted.
2. The Bangalore ITAT held that if a company does not have a split for various services, foreign tax withholding under section 195 will be taxed as royalty.
3. The Mumbai ITAT held that no appeal lies against an order passed under section 195(2) of the Income Tax Act.
809 22 july_2014
This document provides a summary of recent legal landmarks related to taxation in India. It lists 6 cases with details of the authority, section/rules discussed, ratio or key consideration of the case, and citation and name of the assessee involved. Some of the rulings summarized include that reassessment for recharacterizing business advances as capital receipts was not allowed if originally assessed differently, amounts spent on railway construction for project access were revenue expenses, and depreciation of 60% was allowed for chlorine tonners as they are gas cylinders.
811 24 july_2014
This document provides a summary of recent legal landmarks in 6 cases:
1. The ITAT ruled that if a taxpayer does not notify the department of an address change, a notice served on the old address cannot be quashed.
2. The ITAT ruled that interest must be paid on demands sustained in remand proceedings if the initial demand is not paid.
3. The ITAT ruled that projected profits of subsequent years cannot be considered when working out profits under the TNMM transfer pricing method.
4. The Patna HC ruled that an affidavit of gift from a spouse did not adequately explain the source of investments found in a search.
764 30 may_2014
This document provides a summary of recent legal landmarks related to taxation in India. It lists 6 cases by authority, section/rules of relevant law, ratio or key legal principle of the case, citation, and name of party. The first case discusses the determination of net operating profit margin for transfer pricing purposes. The second case concerns the eligibility of a trust for tax exemption where the dominant purpose was benefiting one community. The third case finds that the Settlement Commission cannot order a special audit during settlement proceedings.
827 12 aug_2014
This document provides a summary of recent legal landmarks in India. It lists 6 cases from various High Courts and their key rulings. The cases addressed issues such as what constitutes a permanent establishment for tax purposes, the powers of tax officials to issue notices, whether income from hoardings is taxable, allowability of unused input tax credits, requirements for charitable trust registration, and treatment of government security premiums paid by banks.
1485 25 june 2016
This document provides a summary of recent legal landmarks in India across various tax authorities and high courts. It includes 6 cases covering topics like transfer pricing adjustments, assessment procedures, exemption from capital gains tax, permanent establishment, and deemed income. Each case summary includes the authority, relevant section/rules, key ratio or principle from the ruling, case citation, and name of the assessee involved.
844 1 sep_2014
This document provides a summary of recent legal landmarks related to taxation in India. It lists 6 cases with details of the authority, section/rules discussed, ratio or key consideration, and case name. Some of the cases covered include:
1) A Mumbai tribunal case allowing depreciation on a revalued asset to be transferred to a successor as it was previously allowed to the predecessor.
2) A Gujarat High Court case finding that a director is not liable for unpaid company taxes if the non-recovery is not due to gross negligence of the director.
3) A Delhi High Court case treating disclosure of bank accounts prior to a search as not an admission of undisclosed income.
1484 24 june 2016
This document provides a summary of recent legal landmarks across various high courts and appellate tribunals in India. It lists 6 cases covering topics like penalty for cash transactions from directors, comparability of entities in transfer pricing assessments, definition of speculative transactions, tax deducted at source on procurement of study data, definition of agricultural land, and meaning of royalties in the India-Thailand tax treaty. Each case cited provides the authority, relevant section/rule, ratio or key consideration from the ruling, and citation details.
1493 5 july_2016
This document provides a summary of recent legal landmarks across various tax authorities in India. It lists 6 cases covering topics like the tax treatment of wheeling charges, eligibility for deductions under section 80-I, the taxability of income from carbon credits, condonation of delay in filing an appeal, determining the most appropriate transfer pricing method, and selection of comparable companies for transfer pricing studies. For each case, it provides the authority, relevant section/rules, ratio of the ruling, and case name.
812 25 july_2014
This document provides a summary of recent legal landmarks in taxation. It lists 6 cases from various High Courts and appellate authorities across India. Each case listing includes the authority, relevant section/rule, ratio or key consideration from the case, case citation, and name of the assessee involved. The cases covered rulings on topics like interest income taxation, penalty for change in head of income, use of segmental reports for transfer pricing, stay of tax recovery, classification of rental income, and depreciation allowance.
1498 11 july_2016
This document provides a summary of recent legal landmarks related to taxation in India. It lists 4 cases from the Supreme Court, Delhi High Court, and Mumbai Income Tax Appellate Tribunal. The cases addressed issues related to revisionary orders under section 263, search and assessment procedures under sections 153A and 153C, treatment of purchases as genuine or bogus, and appropriate pricing of corporate guarantees for transfer pricing purposes.
1509 23 july_2016
This document provides a summary of recent legal landmarks from various authorities:
1. The Income Tax Appellate Tribunal (ITAT) ruled that interest must be allowed on tax deducted at source (TDS) refunds.
2. The ITAT classified certain professional fees as independent personal services (IPS) rather than fees for technical services (FTS) under the India-US tax treaty.
3. The ITAT found that benchmarking cannot be done at the entity level when the assessed entity has both international and domestic transactions.
841 29 aug_2014
This document provides a summary of recent legal landmarks across various jurisdictions in India. It lists 6 cases with details of the authority, section/rules discussed, ratios/principles established, and case citations. Key cases include:
1) A penalty order under section 274 of the ITA was held void for not striking irrelevant portions and not specifying if the penalty was for concealment or inaccurate particulars.
2) Property transfer for tax purposes occurs when the sale agreement is entered and part consideration is received.
3) Auctioning plots for maximum revenue alone cannot be considered a profit-making exercise for charitable income taxation.
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2:同时对留学生所学专业登记给予评定
3:国家专业人才认证中心颁发入库证书
4:这个认证书并且可以归档倒地方
5:凡事获得留信网入网的信息将会逐步更新到个人身份内，将在公安局网内查询个人身份证信息后，同步读取人才网入库信息
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本公司拥有海外各大学样板无数，能完美还原。
1:1完美还原海外各大学毕业材料上的工艺：水印，阴影底纹，钢印LOGO烫金烫银，LOGO烫金烫银复合重叠。文字图案浮雕、激光镭射、紫外荧光、温感、复印防伪等防伪工艺。材料咨询办理、认证咨询办理请加学历顾问Q/微741003700
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三.真实教育部学历学位认证（教育部存档！教育部留服网站永久可查）
四.办理各国各大学文凭(一对一专业服务,可全程监控跟踪进度)
如果您处于以下几种情况：
◇在校期间，因各种原因未能顺利毕业……拿不到官方毕业证【q/微741003700】
◇面对父母的压力，希望尽快拿到；
◇不清楚认证流程以及材料该如何准备；
◇回国时间很长，忘记办理；
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留信网认证的作用:
1:该专业认证可证明留学生真实身份
2:同时对留学生所学专业登记给予评定
3:国家专业人才认证中心颁发入库证书
4:这个认证书并且可以归档倒地方
5:凡事获得留信网入网的信息将会逐步更新到个人身份内，将在公安局网内查询个人身份证信息后，同步读取人才网入库信息
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学校原件一模一样【微信：741003700 】《(SCU毕业证书)澳洲南十字星大学毕业证文凭证书》【微信：741003700 】学位证，留信认证（真实可查，永久存档）原件一模一样纸张工艺/offer、雅思、外壳等材料/诚信可靠,可直接看成品样本，帮您解决无法毕业带来的各种难题！外壳，原版制作，诚信可靠，可直接看成品样本。行业标杆！精益求精，诚心合作，真诚制作！多年品质 ,按需精细制作，24小时接单,全套进口原装设备。十五年致力于帮助留学生解决难题，包您满意。
本公司拥有海外各大学样板无数，能完美还原。
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一.毕业证【q微741003700】成绩单、使馆认证、教育部认证、雅思托福成绩单、学生卡等！
二.真实使馆公证(即留学回国人员证明,不成功不收费)
三.真实教育部学历学位认证（教育部存档！教育部留服网站永久可查）
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如果您处于以下几种情况：
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◇不清楚认证流程以及材料该如何准备；
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◇企事业单位必须要求办理的
◇需要报考公务员、购买免税车、落转户口
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留信网认证的作用:
1:该专业认证可证明留学生真实身份
2:同时对留学生所学专业登记给予评定
3:国家专业人才认证中心颁发入库证书
4:这个认证书并且可以归档倒地方
5:凡事获得留信网入网的信息将会逐步更新到个人身份内，将在公安局网内查询个人身份证信息后，同步读取人才网入库信息
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7:个人信誉贷款加10分
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[留学文凭学历认证(留信认证使馆认证)新西兰林肯大学毕业证成绩单毕业证证书大学Offer请假条成绩单语言证书国际回国人员证明高仿教育部认证申请学校等一切高仿或者真实可查认证服务。
多年留学服务公司,拥有海外样板无数能完美1:1还原海外各国大学degreeDiplomaTranscripts等毕业材料。海外大学毕业材料都有哪些工艺呢？工艺难度主要由：烫金.钢印.底纹.水印.防伪光标.热敏防伪等等组成。而且我们每天都在更新海外文凭的样板以求所有同学都能享受到完美的品质服务。
国外毕业证学位证成绩单办理方法：
1客户提供办理新西兰林肯大学新西兰林肯大学毕业证学位证信息：姓名生日专业学位毕业时间等（如信息不确定可以咨询顾问：我们有专业老师帮你查询）；
2开始安排制作毕业证成绩单电子图；
3毕业证成绩单电子版做好以后发送给您确认；
4毕业证成绩单电子版您确认信息无误之后安排制作成品；
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6快递给客户（国内顺丰国外DHLUPS等快读邮寄）
— — — — 我们是挂科和未毕业同学们的福音我们是实体公司精益求精的工艺！ — — — -
一真实留信认证的作用(私企外企荣誉的见证):
1：该专业认证可证明留学生真实留学身份同时对留学生所学专业等级给予评定。
2：国家专业人才认证中心颁发入库证书这个入网证书并且可以归档到地方。
3：凡是获得留信网入网的信息将会逐步更新到个人身份内将在公安部网内查询个人身份证信息后同步读取人才网入库信息。
4：个人职称评审加20分个人信誉贷款加10分。
5：在国家人才网主办的全国网络招聘大会中纳入资料供国家500强等高端企业选择人才。问山娃想买什么想吃什么山娃知道父亲赚钱很辛苦除了书籍和文具山娃啥也不要能牵着父亲的手满城闲逛他已心满意足了父亲连挑了三套童装叫山娃试穿山娃有点不想父亲说城里不比乡下要穿得漂漂亮亮爸怎么不穿得漂亮望着父亲山娃反问道父亲听了并不回答只是吃吃地笑山娃很精神越逛越起劲父亲却越逛越疲倦望着父亲呵欠连天的样子山娃也说困了累了回家吧小屋闷罐一般头顶上的三叶扇彻夜呜呜作响搅得满屋热气腾腾也搅得山娃心烦意乱父亲一的
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- 1. VOLUME NO.: LLAT/1502 OF 2016-17 DATE: 15 July 2016 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ Dear Client, We have pleasure in listing below some of the recent legal landmarks. SrNo Authority Section/Rules RATIO(S) Citation /Subject CASE(NAME OF ASSESSEE) 1.1 DEL ITAT 30 37(1) ITA Expenditure on repairs of rented premises even if huge and accumulated are allowable as revenue expenditure. 1.2 ITA No 5393_2010 Deduction Ikea Trading (India) P Ltd 2.1 RAIP ITAT 37(1) ITA Explanation 2 to s. 37(1) inserted w.e.f. 01.04.2015 is not retrospective. It applies only to CSR expenditure referred to in s. 135 of the Companies Act and not to voluntary CSR expenditure which is fully allowable 2.2 ITA No 99_2012 Deduction Jindal Power Limited 3.1 BOM HC 143(3) 147 148 ITA S 148 notice issued to and reassessment order passed on a non-existing entity is without jurisdiction. A writ petition can be entertained despite the presence of alternate remedy 3.2 WP No 1069_2016 Assessment Jitendra Chandralal Navlani 4.1 SC 68 whether sum received as foreign gift could be considered as undisclosed income ? LLP granted 4.2 71TM049 Income from CC Sandeep Goyal 5.1 KOL ITAT 92C In respect of the services received from AE the ALP couldnt be fixed as Nil if third party had paid price for such services 5.2 71TM057 Transfer Pricing N L C Nalco (India) Ltd 6.1 MUM ITAT 5 contractor raised invoices on contractee which rejected the same due to bankruptcy- there is no accrual 6.2 71TM062 Accrual Income Bechtel International Inc