784 23 june_2014
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This document provides a summary of recent legal landmarks in various tax cases: 1. The Supreme Court ruled that a company that paid dividend distribution tax on dividends declared at an AGM could not also be held liable under section 115-O. 2. The Pune Income Tax Appellate Tribunal ruled that a company cannot be considered a persistent loss-making entity, and excluded from comparability analysis, if it earned a profit in one of the last three years. 3. The Bombay High Court ruled that rental income received by individual partners from a tenancy belonging to them personally could not be added to the income of an assessee firm.
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2) Retrospective tax amendments not applicable for payments made before the amendment came into effect.
3) Interest on a housing loan disallowed due to maximum limit cannot be set off against other interest income.
4) No addition for amounts received as shared portfolio tracking fees from agents.
5) Comparable companies cannot be excluded from transfer pricing analysis just because included previously.
6) Interest is payable on tax dues of non-res
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.
762 28 may_2014
This document provides a summary of recent legal landmarks across various cases:
1. In the case of Aberdeen Claims Administration Inc, the Authority for Advance Rulings held that the cost of acquiring the surrender of right to sue cannot be determined and capital gains cannot be calculated or taxed in this case.
2. In Abhinandan Investment Ltd, the Delhi High Court held that money forgone by the company in subscribing to non-convertible debentures was allowable as a business loss as it was done for commercial expediency and the business interest of the other company.
3. In Acclaris Business Solutions (P.) Ltd, the Kolkata Income Tax Appellate Tribunal set
782 20 june_2014
This document provides a summary of recent legal landmarks related to taxation in India. It lists 6 cases from various High Courts and Income Tax Appellate Tribunals across India. For each case, it provides the authority, relevant section/rules, ratio/principle of the ruling, citation details, and name of the assessee involved. The rulings addressed issues like the applicability of stamp duty value for capital gains, deductions for scientific research expenditures, depreciation eligibility for licensees, time barring of block assessments, allowability of leave encashment on payment basis, and collection/recovery of penalty amounts in search related cases.
1479 18 june 2016
This document provides a summary of recent legal landmarks across various authorities and jurisdictions in India. It lists 6 cases covering topics like assessment of firms, royalty deductions, municipal tax deductions, winding up petitions of foreign companies, deemed grant of charity registration, and taxability of discounting charges. Each case provides the authority, section/rules cited, key ratio or ruling, and case name and citation.
808 21 july_2014
Recent legal landmarks in taxation are summarized:
1. The ITAT ruled that sale-tax loan remission on prepayment would not be deemed as liability remission. It also ruled that delay in debt recovery from an associated enterprise is an international transaction subject to transfer pricing rules.
2. The ITAT held that a longer credit period allowed to an associated enterprise on sale proceeds realization is an international transaction under transfer pricing.
3. The ITAT stated that exemption cannot be denied if a booking amount is paid over a year before property transfer.
4. The High Court ruled that payments to a consultant-doctor without work hour stipulations would attract tax deducted at source.
5. The
807 19 july_2014
This document provides a summary of recent legal landmarks across various authorities and courts in India. It lists 6 cases covering topics like concealment penalty on a foreign company's liaison office, allowability of business expenses on commission paid by a distributor to sub-distributor, quashing of an order of revision when grounds differed from notice, income being taxable on accrual basis when following mercantile accounting, preponement of hearing not invalidating a valid transfer order when additional time was given to file submissions, and reasons for reassessment specifically indicating undisclosed material facts.
1529 16 aug_2016
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 of the Income Tax Act involved, ratios or principles established, case names and citations. The cases addressed issues like determining comparable companies for transfer pricing, allowability of depreciation and interest deductions, applicability of transfer pricing provisions, penalties for furnishing inaccurate income particulars, selection of the tested party under transfer pricing regulations, and benchmarking transactions with associated enterprises.
733 23 april_2014
This document provides a summary of recent legal landmarks across various authorities and courts in India. It lists 6 cases with details of the section/rule and ratio decided. The first case discusses recovery of excess payment made to an employee. The second case discusses that benefit of section 10(23G) cannot be denied due to amalgamation. The third case discusses that tribunal order can recall its earlier dismissal order and decide on merits.
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.
1495 7 july_2016
1. The Supreme Court ruled that tips collected by employees from customers cannot be considered as salary income of the employees and are not taxable.
2. The Mumbai ITAT ruled that since a celebrity was advised by a competent CA regarding tax provisions, no penalty could be imposed for failure to deduct tax at source since there was no mala fide intention.
3. The Cochin ITAT ruled that mere proximity of land to a highway does not change the agricultural nature of the land, and appreciation in land value alone cannot be used to determine if the land is not agricultural.
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.
793 3 july_2014
1. The document lists recent legal landmarks from various courts and tribunals in India relating to taxation.
2. It summarizes six cases, providing the section/rules of the Income Tax Act involved, a brief description of the ratio (legal principle) decided, and the citation and subject of the case.
3. The cases addressed a range of issues including what material is needed from the assessing officer to justify a settlement demand, when a preliminary notice needs to be issued for a settlement application, when penalty can be levied for documents related to a group of companies, and whether certain types of orders and deductions are appealable.
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原版制作(PSU毕业证书)宾州州立大学公园分校毕业证学历证书一模一样
学校原件一模一样【微信：741003700 】《(PSU毕业证书)宾州州立大学公园分校毕业证学历证书》【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。
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
【主营项目】
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）
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；
◇回国马上就要找工作，办给用人单位看；
◇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
◇申请留学生创业基金
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
6:个人职称评审加20分
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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
【主营项目】
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）
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；
◇回国马上就要找工作，办给用人单位看；
◇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
◇申请留学生创业基金
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
6:个人职称评审加20分
7:个人信誉贷款加10分
8:在国家人才网主办的国家网络招聘大会中纳入资料，供国家高端企业选择人才
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【业务选择办理准则】
一、工作未确定，回国需先给父母、亲戚朋友看下文凭的情况，办理一份就读学校的毕业证【微信bwp0011】文凭即可
二、回国进私企、外企、自己做生意的情况，这些单位是不查询毕业证真伪的，而且国内没有渠道去查询国外文凭的真假，也不需要提供真实教育部认证。鉴于此，办理一份毕业证【微信bwp0011】即可
三、进国企，银行，事业单位，考公务员等等，这些单位是必需要提供真实教育部认证的，办理教育部认证所需资料众多且烦琐，所有材料您都必须提供原件，我们凭借丰富的经验，快捷的绿色通道帮您快速整合材料，让您少走弯路。
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
6:个人职称评审加20分
7:个人信誉贷款加10分
8:在国家人才网主办的国家网络招聘大会中纳入资料，供国家高端企业选择人才
【关于价格问题（保证一手价格）】
我们所定的价格是非常合理的，而且我们现在做得单子大多数都是代理和回头客户介绍的所以一般现在有新的单子 我给客户的都是第一手的代理价格，因为我想坦诚对待大家 不想跟大家在价格方面浪费时间
对于老客户或者被老客户介绍过来的朋友，我们都会适当给一些优惠。
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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
【主营项目】
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）
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；
◇回国马上就要找工作，办给用人单位看；
◇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
◇申请留学生创业基金
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
6:个人职称评审加20分
7:个人信誉贷款加10分
8:在国家人才网主办的国家网络招聘大会中纳入资料，供国家高端企业选择人才
在线办理(UNE毕业证书)新英格兰大学毕业证成绩单一模一样
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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
【主营项目】
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The Work Permit for Self-Employed Persons in Italy
Learn more on how to obtain the work permit for self-employed persons in Italy at https://immigration-italy.com/selfemployment-work-permit-in-italy/.
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784 23 june_2014
- 1. VOLUME NO.: LLAT/784 OF 2016-17 DATE: 23 June 2014 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ 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 SC 115-O 115P 263 ITA Where A paid dividend distribution tax on dividend declared in AGM A could not be held liable under section 115-O. 1.2 54TM135 Tax on distributed profits BMW Industries Ltd 2.1 PUN ITAT 92C ITA Company which earned profit in one of last three years could not be considered as loss making entity so as to exclude same from comparability analysis as persistent loss making means continuous loss making for more than 3 years . 2.2 63TM339 Transfer Pricing Bobst India (P.) Ltd 3.1 BOM HC 4 ITA Tenancy of rental premises belonged to individual partners and not to assessee-firm and consideration was received by partners in individual capacity addition made in income of assessee-firm was not justified. 3.2 55TM422 Chargeability Bombay Electric Laundry 4.1 DEL ITAT 271(1)(c) 92C ITA Penalty could not have been imposed simply because transfer pricing addition was accepted by A. 4.2 67TM288 Penalty Boston Scientific India (P.) Ltd 5.1 DEL HC 4 ITA Entertainment tax subsidy would be considered as capital receipt even though the source was the public who visit the cinema hall after it becomes operational. 5.2 ITA No 586_2013 Chargeability Bougainvillea Multiplex Entertainment 6.1 BOM HC 37(1) 263 ITA Since amount paid by A to buy-back shares of one group of shareholders was only for purpose of ensuring that it could run its business smoothly and more profitably therefore the amount was allowable as revenue expenditure. 6.2 63TM013 Deduction Bramha Bazar Hotels Ltd