847 4 sep_2014
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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 Indian Income Tax Act involved, key ratio decided, case name and citation. The cases relate to topics such as interest income earned by cooperative societies being deductible, interest income of finance companies being taxable as business income, interest on non-performing assets not being taxable, appropriate benchmark for interest on loans to foreign affiliates, interest paid after business operations not being capitalized, and internal transactional net margin method not being rejected solely due to insignificant non-affiliate transactions.
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This document provides a summary of recent legal landmarks across various authorities and cases. It lists 6 cases with details including the authority, section/rules discussed, ratios or principles established, and case names. The cases cover topics like securities transaction tax not being applicable to stock exchanges, penalty not being leviable due to mistakes in online tax return filing, appellate orders needing to consider precedents to avoid breaching natural justice, hotel income being eligible for business deductions, and securities needing to be treated consistently as investments or not business income year over year.
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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.
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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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This document provides a summary of recent legal landmarks from various authorities:
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This document provides a summary of recent legal landmarks across various tax authorities in India. It lists 6 cases from different High Courts and Tax Appellate Tribunals pertaining to sections like 92C, 2(22), 80HHC, 40(a)(ia), 48, and 145 of the Income Tax Act. Each case provides the section number, ratio or key legal principle established, citation details, and name of the taxpayer involved. The document summarizes important tax rulings on issues like transfer pricing, deemed dividend, deductions, disallowances, capital gains computation, and accounting methods.
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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.
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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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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.
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This document provides a summary of recent legal landmarks in Indian tax law. It lists 6 cases from various High Courts and the Income Tax Appellate Tribunal. The cases addressed issues such as disallowance of expenses due to TDS default, reassessment of income, tax chargeability, deemed income, and tax deductibility at source for payments made abroad. The document identifies the authority, section/rules of the Income Tax Act involved, key ratio of each case, and citation details.
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The document lists recent legal landmarks from various authorities:
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2. The Delhi HC ruled that a garnishee's statement can be scrutinized under section 226 without examining the nature or existence of liability.
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829 14 aug_2014
1. The document lists recent legal landmarks from various tax authorities and courts.
2. It summarizes six cases, providing the section/rules considered, key ratio or principle from the ruling, citation details and case name.
3. The cases addressed issues like the validity of a scrutiny assessment, determining the arm's length price of royalty payments, treatment of forex losses in computing arm's length price, the taxability of income from letting out office space, restrictions on property transfers, and the deductibility of interest expenses.
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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 Indian Income Tax Act involved, key ratio decided, case name and citation. The cases relate to topics like deduction under section 80-IB, block assessment, penalty for non-filing of audit form, computation of capital gains, deduction for feasibility study expenditure, and tax collection at source on sale of imported goods.
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847 4 sep_2014
- 1. VOLUME NO.: LLAT/847 OF 2016-17 DATE: 4 September 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 KAR HC 80P ITA Interest earned by society on short-term deposits in course of providing credit facilities was deductible u/s 80P 1.2 55TM447 Deductions Tumkur Merchants Souharda Credit Cooperative Ltd 2.1 MUM ITAT 28(i) 37(1) 56 ITA Interest income of finance co. not taxable as other sources of income if it was held as business income in earlier yrs 2.2 63TM023 Business income Preimus Investment & Finance Ltd 3.1 PUN ITAT 4 ITA Interest on NPAs even if credited to the Profit & loss account is not chargeable to tax 3.2 ITA No 495_2012 Chargeability The Solapur District Central Co-op. Bank Ltd 4.1 PUN ITAT 92C ITA Interest on sums lent to foreign AE is to be benchmarked at LIBOR and not at domestic prime lending rate 4.2 54TM384 Transfer Pricing Varroc Engineering (P.) Ltd 5.1 GUJ HC 43(1) 32 37(1) ITA Interest paid after execution of slump sale and initiation of business operations couldnt be capitalized 5.2 55TM453 Definitions Sandvik Chokshi Ltd 6.1 HYD ITAT 92C ITA Internal TNMM couldnt be rejected just because value of transaction with non-AE was insignificant 6.2 63TM092 Transfer Pricing NTT Data Global Delivery Services Ltd