1513 28 july_2016
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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.
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1481 21 june 2016
This document provides a summary of recent legal landmarks from various tax authorities in India. It lists 6 cases from different High Courts and Income Tax Appellate Tribunals (ITATs) across India. The cases pertained to topics like transfer pricing adjustments, penalty for transfer pricing additions, selection of comparable companies for transfer pricing analysis, tax treatment of consideration paid to original promoter, need for segmental profit analysis in transfer pricing cases, and taxability of anonymous donations. For each case, the document mentions the authority, relevant section/rule, ratio or key consideration of the ruling, and case name.
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.
1526 12 aug_2016
The document provides a summary of recent legal landmarks in Indian tax law. It lists 6 cases with the section/rules of the Indian Income Tax Act involved, a brief description of the ratio or key legal principle from each case, and the citation and name of the assessed party. The cases addressed issues such as whether debentures issued in lieu of interest could be considered an actual payment; whether expenses incurred prior to incorporation of an associated enterprise constituted an international transaction; and whether the actual usage or ready availability of an oil rig was necessary to constitute a permanent establishment.
1506 20 july_2016
This document provides a summary of recent legal landmarks in India across various tax authorities and courts. It lists 6 cases covering topics like transfer pricing regulations, accounting methods for expenses, deductions allowable for stamp duty and compounding fees, and the principle of mutuality for housing societies. Each case provides the authority, relevant section/rules, ratio or key consideration from the ruling, and citation details. The document aims to keep clients informed about important tax law developments.
1480 20 june 2016
This document provides a summary of recent legal landmarks in India across various subjects:
1. The Mumbai ITAT ruled that a business with two sources of income cannot use cash accounting for one source and mercantile accounting for the other.
2. The Mumbai ITAT found that the TPO was not justified in aggregating and benchmarking all of a company's international transactions using TNMM when the company used different accounting methods.
3. The Karnataka High Court deleted an entire income tax addition based on income estimation since the company's books of account had not been rejected.
4. The Mumbai ITAT found a tax reassessment invalid when the notice was issued to an Indian group company but action was
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.
1520 5 aug_2016
This document lists recent legal landmarks from various authorities:
1. The ITAT ruled that interest under section 234B will apply from the first day of the assessment year once an order is passed under section 245C.
2. The ITAT held that a trust letting out its auditorium for marriage functions will not be eligible for exemption under the Income Tax Act.
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.
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.
1499 12 july_2016
This document provides a summary of recent legal landmarks in various tax cases:
1. The ITAT ruled that merely supplying goods to another party does not make them an associated enterprise under section 92A of the ITA.
2. The ITAT ruled that the DRP proceedings are an extension of the assessment proceedings and the DRP can accept new comparables under section 144C of the ITA.
3. The High Court ruled that penalty is attracted automatically under section 272A of the ITA for delay in filing TDS returns, regardless of whether there was any loss to revenue.
788 27 june_2014
1. The document lists recent legal landmarks from various tax authorities and courts in India.
2. It summarizes six cases, noting the section/rules and ratios involved, related to issues like transfer pricing adjustments, treatment of interest and commission income, disallowance of interest expenses, filing fees, and treatment of reimbursements to overseas companies for seconded employees.
3. The cases cover judgments from the Delhi Income Tax Appellate Tribunal, Gujarat High Court, Kolkata High Court, Hyderabad Income Tax Appellate Tribunal, and Supreme Court of India.
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◇面对父母的压力，希望尽快拿到；
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1513 28 july_2016
- 1. VOLUME NO.: LLAT/1513 OF 2016-17 DATE: 28 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 CHENN ITAT 92C when payment is not made on behalf of AE it is not a pass through cost 1.2 70TM259 Transfer pricing Lason India (P.) Ltd. 2.1 DEL ITAT 92C Event Management Co. and business support services co can be comparables 2.2 70TM260 Transfer pricing Eli Lilly & Co. (India) (P.) Ltd 3.1 PUN ITAT 37(1) 36(1)(iii) Interest on share application money is business expenditure 3.2 70TM261 Deduction S.R.Thorat Milk Products (P.) Ltd. 4.1 MUM ITAT 92C Content developer and TV channels are not comparables 4.2 70TM272 Transfer pricing Star India (P.) Ltd. 5.1 BANG ITAT 92C Co A and Co 10 x A are not comparable 5.2 70TM273 Transfer pricing Sunquest Information Systems (India) (P.) Ltd 6.1 RAJ HC 268A Appeal filing limits are retrospective 6.2 70TM275 Appeal Smt. Manbhar Devi Meena