LL 483
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The document is a letter from Anand Mehta & Co. consultants summarizing recent legal landmarks and rulings on taxation issues in India. It includes 6 rulings covering topics such as determining a business connection for cargo shipment for tax purposes, eligibility for tax deductions for manufacturing activities, what constitutes a capital asset for capital gains tax, an assessment can be questioned even if a previous ruling on the issue was not appealed, and what date determines jurisdiction for advance tax rulings. Contact information is provided for the consulting firm.
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Legal landmark 531
This document provides a summary of recent legal landmarks in 6 areas:
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This document provides a summary of recent legal landmarks in 6 areas of tax law:
1) Situs of income for foreign agents and requirement to deduct tax from commission payments.
2) Claim of expenditure on interest for investments even when dividend income is not taxable or company is running at losses.
3) Addition of unexplained expenditure even if proof of source of funds is provided.
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This document provides a summary of recent legal landmarks in 6 areas:
1) When foreign personnel work on projects in India, they can be considered employees of the foreign company.
2) For tax reassessment, it is sufficient if income was missed, but failure to disclose facts must be proven for proviso cases.
3) Reassessment cannot be initiated if amalgamation dates match scheme dates.
4) Transfer pricing adjustments must be made if transactions are not at arm's length, regardless of other provisions.
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This document lists recent legal landmarks in India, including several court cases and their key rulings. It covers topics like taxation exemptions, income tax deductions, the definition of permanent establishment under tax treaties, validity of income tax notices, treatment of advance money received, forfeiture of amounts received for setting up businesses, and more. The letter from Anand Mehta & Co. consultants provides this legal update and references to help clients stay informed of important changes in Indian law.
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This document provides a summary of recent legal landmarks in 6 areas of tax law:
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3) Addition of unexplained expenditure even if proof of source of funds is provided.
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1. The document provides a summary of recent legal landmarks across various authorities and high courts in India.
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LLAT 494
The document is a letter from Anand Mehta & Co. consultants providing a summary of recent legal landmarks related to taxation. It includes 6 sections that each list a legal authority, relevant section/rules, and a brief summary of the ratio or key finding of a case related to that section. The letter offers to provide more information on any of the cases and landmarks summarized.
LL 471
The document is a letter from Anand Mehta & Co. PVT. LTD to a client listing recent legal landmarks and rulings on taxation issues. It includes 6 sections each with an authority citation, relevant section/rule, and a brief summary of the ratio and case name. The letter provides this information as a legal reference resource and offers further details if needed. It closes by thanking the client and assuring their best ongoing services.
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This document lists recent legal landmarks in India, summarizing key cases. It includes 6 sections each with a citation from the Delhi Tribunal, Authority, section/rules discussed, and key ratio(s) or legal principle(s) established. Each legal landmark includes the name of the relevant case. The letter thanks the client for their business and assures best services.
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This document provides a summary of recent legal landmarks and rulings across various sections of Indian tax law. It lists 6 key cases or rulings pertaining to sections like 92B on international transactions, section 48 on indexation of preference shares, section 9 and 115A on fees for technical services and deemed income from foreign sources, and section 14A on disallowance of expenses. For each ruling, it provides the section or rule addressed, key ratios or principles laid down, and the name of the assessed party in the case. The document was sent by Anand Mehta & Co. consultants to a client to update them on the latest tax jurisprudence.
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The document is a letter from Anand Mehta & Co. consulting firm providing a client with a summary of recent legal landmarks and rulings. It includes 6 cases with details of the section/rules and key ratio discussed. Case 1 discusses the obligation of a taxpayer to provide documentation for transfer pricing inquiries. Case 2 addresses amounts paid/received being included for special provisions for oil exploration. Case 3 excludes functionally different software companies from a taxpayer's transfer pricing comparables. Case 4 limits the taxation of a non-resident enterprise's profits to the contracting state and amounts attributable to a permanent establishment in another state. Case 5 states that treaty applicability must be examined separately for different countries of royalty receipt. Case 6 addresses the need for declaration
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This document provides a summary of recent legal landmarks in 6 areas of tax law:
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2) Subscription fees received for social media monitoring services are considered royalty and taxable under section 9.
3) Penalty under section 271D for cash loans over Rs. 20,000 is not applicable if each loan is less than Rs. 20,000 even if total is over the limit.
4) Exemption under section 13 is only available for trust income not applied for the benefit of any person listed under section 13(3).
5) Extended limitation period is available to the AO even if
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This document provides a summary of recent legal landmarks in 6 sections. Each section includes the authority and section/rules cited, a brief summary of the legal ratio, and a reference to a relevant case. The summaries address topics such as the deductibility of interest on loans to subsidiaries, the tax treatment of gains from land sales, interest payments on tax refunds, the taxability of share sale profits, and the tax implications of violations of company ownership provisions. The document is from a legal consulting firm and offers further information on these cases.
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1. The document provides a summary of recent legal landmarks across various authorities and high courts in India.
2. It lists 6 cases, with details of the section/rules and ratios involved. The first case discusses working capital adjustments in transfer pricing cases. The second case concerns whether merely being a lifelong member of a trust implies it is non-charitable. The third case is about denial of trust registration solely based on seized documents about capitation fees.
3. The remaining cases cover issues like carrying forward income by charitable trusts, differences between portfolio management and investment advisory services, and condonation of delay in filing an appeal due to employee resignation.
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This document provides a summary of recent legal landmarks in India related to taxation. It lists 6 key cases from various High Courts and Income Tax Appellate Tribunals (ITAT) pertaining to sections of the Income Tax Act such as capital gains, deductions, transfer pricing adjustments, and registration of charitable trusts. For each case, it provides details such as the authority, relevant section/rule, key ratio decided, and name of the assessed party. The director of the consulting firm Anand Mehta & Co. shares this summary of legal rulings with a client and offers to provide any further information needed.
Legal landmark 506
This document is a letter from Anand Mehta & Co. consulting firm listing recent legal landmarks and case rulings. It includes 6 cases summarized with the case name, authority, relevant section/rule, and key ratio. The cases cover topics like capital gains tax exemptions, transfer pricing assessments, business expense deductions, and applicability of double taxation treaties. The letter is providing this information to an unnamed client and offers additional assistance if needed.
LL 453
This document provides a summary of recent legal landmarks in India based on case law and tribunal rulings. It includes 6 sections summarizing rulings related to sections 132, 115A, 57, 10, 40, and 92 of the Income Tax Act of India. Each section lists the authority, sections or rules addressed, key ratios or outcomes, and citations for relevant cases such as Jeet Construction Co., DE BEERS UK, Sasan Power Ltd., and Birlasoft India LTD. The document was sent by Anand Mehta & Co. consultants to provide a client with information on recent tax case law developments.
LL 480
This document is a letter from Anand Mehta & Co. consultants summarizing recent legal landmarks in taxation. It lists 6 recent cases with details of the section/rule, ratio, and case name. The cases cover topics like capital gains taxability of termination payments, eligibility of software customization for tax incentives, impact of using irrelevant material in court findings, deemed dividend provisions, issue-specific nature of transfer pricing references, and TDS applicability to transport payments. The letter is providing this information to the client and assures of their best services.
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Legal landmark 538
This document provides a summary of recent legal landmarks related to taxation. It lists 6 cases with details about the section/rules and key ratios involved. The cases cover topics such as capitalization of expenditures, allowability of software expenses, artificial capital losses between sister concerns, taxability of income without a permanent establishment, concealment penalties, and Section 80-IA benefits. The document was sent by Anand Mehta & Co. consultants to inform the client of these legal updates in taxation.
Legal landmark 536
This document provides a summary of recent legal landmarks and rulings on taxation issues in India. It lists 6 key cases by court or tribunal, relevant section/rules, and a brief summary of the ratio or key ruling. The cases cover issues like service tax registration requirements, tax treatment of fees paid abroad, and whether certain payments qualify as royalties or technical fees. The letter is from a consulting firm providing this legal update to a client.
Legal landmark 534
This document provides a summary of recent legal landmarks or case rulings across various sections of the Indian Income Tax Act. It lists 6 key rulings related to sections 14A, 28, 80IB, 80IA, 194J and 32. For each ruling, it provides the section/rules cited, a brief description of the ratio or legal principle established, and a reference to the case name and TIOL citation. The document was sent by Anand Mehta & Co. consultants to a client, informing them of these updates and offering further information if required.
Legal landmark 532
This document provides a summary of recent legal landmarks in 6 sections. Each section includes the authority citation, relevant section or rule, a brief summary of the legal ratio, and a reference case. Key ratios summarized include: the limitation period for assessment in search cases runs from the conclusion of the search, not a later date; capital gains tax applies to property transferred to a partner upon firm dissolution; and income from share transactions held for less than 12 months is considered short-term capital gains. The document is from a legal consultancy firm and offers additional information on the cases.
Legal landmark 529
This document provides a summary of recent legal landmarks in India related to taxation. It lists 6 cases with details of the section/rules and key ratio decided. The cases cover topics like composite contracts, bad debt deductions, penalties for undisclosed income, fees for services taxable in India, treatment of losses from government securities, and tax deducted at source. The client is thanked and assured of best services.
Legal landmark 528
This document provides a summary of recent legal landmarks in India. It lists 6 key cases with details of the section/rules addressed, key ratios or principles from the case, and case names. The document was sent by Anand Mehta & Co. consultants to a client to inform them of notable recent legal precedents across various tax issues. It aims to keep the client updated on important case laws.
Legal landmark 527
This document provides a summary of recent legal landmarks in India. It lists 6 cases from various High Courts and Income Tax Appellate Tribunals across India. Each case listing includes the court or tribunal, relevant section/rules of law, and a brief 1-2 sentence description of the legal ratio or principle from each case. The document was sent by Anand Mehta & Co. Pvt. Ltd. to a client to inform them of notable recent legal rulings and offer additional information if needed.
Legal landmark 526
This document provides a summary of recent legal landmarks in India related to taxation. It lists 6 cases from various High Courts and Income Tax Appellate Tribunals (ITAT) covering topics such as what constitutes taxable income, whether income should be taxed as business or investment, when capital gains tax applies, transfer pricing regulations, deducting tax at source, and more. For each case, it provides the case name and citation, relevant section/rule of tax law, and a brief summary of the key ratio or legal principle from the ruling. The document was sent by Anand Mehta & Co. consultants to a client to inform them of updates in tax law.
Legal landmark 525
This document lists recent legal landmarks from court rulings and tribunal cases. It includes 6 cases covering topics like deemed dividend, royalty payments for software use, claiming bad debt deductions, rejection of speculative loss set-off penalties, rights of third members in tribunals, and taxation of capital gains from land sale. Contact details are provided for the law firm compiling the document if more information is needed on the cases.
Legal landmark 522
This document provides a summary of recent legal landmarks in 6 areas:
1) Project management services taxability and applicability of DTAA provisions
2) Computation of book profits and rectification
3) Profits taxable based on permanent establishment and transfer pricing
4) Risk adjustment for comparables in determining arm's length price
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6) Charitable status extension to animal welfare organizations
Legal landmark 521
This document provides a summary of recent legal landmarks related to taxation in India. It lists 6 cases covering topics like TDS obligations, undisclosed income estimation, capital gains valuation, penalty for late surrender of income, separate legal status of companies, and classification of income from a market complex. For each case, it provides the section/rules addressed, key legal ratios decided, and case name. The director of the consulting firm providing this summary offers to provide any further details needed on these cases.
Legal landmark 520
This document lists recent legal landmarks from various authorities and courts related to taxation. It includes 6 sections that each contain a citation to an authority, the relevant section or rule, a brief description of the ratio or reasoning of a case, and the name of the assessed party. The letter provides this information to a client and offers to provide further details on the legal landmarks. It is signed by the director of Anand Mehta & Co., Consultants Pvt. Ltd.
Legal landmark 519
This document is a letter from Anand Mehta & Co. consultants listing recent legal landmarks related to taxation. It provides 6 sections each with a citation from a tax authority and case name. For each case it summarizes the key ratio or ruling such as income from licensing property is taxed as other income not house property. It requests the client to contact them if more information is needed on the cases cited.
Legal landmark 518
This document lists recent legal landmarks from various authorities and courts related to taxation. It provides the section or rules and a brief summary of the ratio or key point of each case cited. Cases cover topics like deductibility of penalties, treatment of corpus funds, deemed consideration, tax deductions on credit balances, profit from sale of business assets, and treatment of unclaimed dividends. The client is thanked and assured of best services.
Legal landmark 517
The document is a letter from Anand Mehta & Co. consultants listing recent legal landmarks related to taxation. It provides 6 main points each with a citation from a legal authority and court case. For each point it lists the section or rule and a brief description of the legal ratio or principle from the cited case. The letter offers to provide more information on the legal rulings and assures the client of their best services.
Legal landmark 516
This document is a letter from Anand Mehta & Co. consulting firm listing recent legal landmarks and case rulings. It includes 6 sections each with a citation and brief description of a legal ratio or case related to topics like the Indian Income Tax Act, capital gains tax, business expenses, and unexplained deposits. The firm offers to provide more information on the cases and issues covered in the letter.
Legal landmark 512
This document provides a summary of recent legal landmarks in 6 areas of tax law:
1. The Delhi High Court ruled that interest income and transportation charges do not qualify for tax deductions.
2. The Ahmedabad ITAT ruled that if the main purpose of an asset transfer was to claim excess depreciation and reduce taxes, the AO can apply an explanation to section 43(1) to substitute the actual cost.
3. The Kerala High Court ruled that if undisclosed income assessed is more than declared, the assessee is not entitled to penalty immunity.
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Legal landmark 511
This document provides a summary of recent legal landmarks in India. It lists 6 key cases or rulings from various authorities like the Hyderabad ITAT, Karnataka High Court, Kolkata ITAT, etc. For each case, it provides the section/rules involved, a brief description of the ratio or legal principle established, and the name of the relevant party. The document was sent by Anand Mehta & Co. consultants to inform a client about important legal updates over the past year.
Legal landmark 510
This document provides a summary of recent legal landmarks in India. It lists 6 cases from various High Courts and Income Tax Appellate Tribunals related to sections of the Income Tax Act of India including sections 9, 21, 43B, 147, 260A, and 2(14). For each case, it provides the section/rules addressed, a brief description of the ratio or legal principle, and case name. It was sent by Anand Mehta & Co. consultants to keep the client informed of updates in tax law.
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LL 483
- 1. VOLUME NO.: LLAT/ 483 OF 2012-13 DATE: 7 th May, 2012 Dear Client, We have pleasure in listing below some of the recent legal landmarks. SR. AUTHORITY SECTION / RULES / RATIO(S) NO. CITATIONS SUBJECT CASE(NAME OF ASSESSEE) 1.1 MUM ITAT 163, ITA A' company carrying on business of cargo consolidation having engaged the services of the non-resident for transshipment of cargo to foreign destinations on the terms and conditions imposed by the letter, the business activity of shipment of cargo cannot be segregated as one up to the port of transshipment and the other from the port of transshipment to the port of final destination and thus, there was a business connection. 1.2 143 TTJ 423 DTAA WSA Shipping P.Ltd. 2.1 MUM ITAT 80-IB, ITA Activity on sending, hand carving, fitting, staining, painting, polishing, spraying, antiquing, packing etc. carried out by the 'a' at its factory through its own employed workers/artisans as well as through contract workers/artisans to produce handmade wooden articles or things come within be meaning of the words 'manufacture' or 'produce' and, therefore, 'a' has satisfied the main condition for entitlement of deduction. 2.2 144 TTJ 56 Deduction Arts & Crafts Exports 3.1 CHENN ITAT 45, ITA Assignment of land by the 'a' company towards joint venture with another company for development thereof into a commercial complex which is to be compensated by 50 per cent rights in the built-up area did not amount to transfer of a capital asset as nothing happened in the relevant year other than the execution of the agreements and the 'a' cannot be said to have sold or extinguished or relinquished any of its existing assets/rights to the Co- venturer and, therefore, no capital gains are chargeable in the relevant year. 3.2 144 TTJ 1 Cap Gains Vijaya Productions P.Ltd 4.1 SC 143, ITA Merely because the order of the Sp. Bench of the Tribunal relating to earlier 'a' years was not assailed in appeal by the Department, itself, it cannot take away the right of the Revenue to question the correctness of the assessment order on the same issue in the relevant AY, particularly when a question of law is involved which goes to the very root of the matter. 4.2 248 CTR 1 Assessment Catholic Syrian Bank Ltd. 5.1 AAR 245, ITA It is necessary to have a fixed common point or event for determining the existence or absence of jurisdiction. Thus, the definite point should be the date of filing of return juxtaposed with the filing of the return is the relevant date to consider the applicability of the provision. Consequently, since the return filed by the applicant generates questions including those raised before the authority, the jurisdiction to give a ruling in the present case is barred. 5.2 248 CTR 27 Procedure Wavefield Inseis ASA 6.1 KAR-HC 9, ITA Liaison Office of Korean company concluding contracts and securing orders in India constitutes permanent Establishment 6.2 124 (I) TR DTAA Jebon Corporation India Liaison Office Please let us know if you need any further information on these. Thanking you and assuring you of our best services at all times. Yours Faithfully, For Anand Mehta & Co ., (CONSULTANTS) PVT. LTD. Anand V. Mehta DIRECTOR A mind of a consultant with a heart of a friend. Mumbai Office- 334, Mulratna 1st Floor Narshi Natha Street Masjid (W) Mumbai 40009 Tel -022- 23400882 • Fax-022-23420195 • E-mail: amcon.mumbai@amcount.com Pune Office –B/5 Shardaram Park, 34, Sasson Road, Near Jehangir Hospital, Pune - 411 001 Tel-020 6401 3124 • Fax 020- 30521223•E-mail: amcon.pune@amcount.com Gram-MATERPLAN <--> MASTERPLAY Website:www.amcount.com