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Income Tax Appellate Tribunal Case Commentaries

Limits on Revisional Powers under Section 263: Shoreline Hotel (P.) Ltd. v. Commissioner of Income-Tax

Limits on Revisional Powers under Section 263: Shoreline Hotel (P.) Ltd. v. Commissioner of Income-Tax

Date: Sep 12, 2018
Limits on Revisional Powers under Section 263: Shoreline Hotel (P.) Ltd. v. Commissioner of Income-Tax Introduction The case of Shoreline Hotel (P.) Ltd. v. Commissioner of Income-Tax, Central-I,...
Commissioner of Income-tax, Delhi v. Bharat Hotels Ltd.: New Precedents on Deemed Dividend and Section 43B Deductions

Commissioner of Income-tax, Delhi v. Bharat Hotels Ltd.: New Precedents on Deemed Dividend and Section 43B Deductions

Date: Sep 7, 2018
Commissioner of Income-tax, Delhi v. Bharat Hotels Ltd.: New Precedents on Deemed Dividend and Section 43B Deductions Introduction The case of Commissioner of Income-tax, Delhi v. Bharat Hotels Ltd....
Reopening Assessments and Unexplained Credits: Insights from Pee Aar Securities Ltd. v. DCIT

Reopening Assessments and Unexplained Credits: Insights from Pee Aar Securities Ltd. v. DCIT

Date: Aug 24, 2018
Reopening Assessments and Unexplained Credits: Insights from Pee Aar Securities Ltd. v. DCIT Introduction The case of M/s. Pee Aar Securities Ltd., New Delhi v. DCIT, New Delhi adjudicated by the...
Arm's Length Remuneration and Its Impact on Permanent Establishment: ESS Advertising v. Deputy Director of Income Tax

Arm's Length Remuneration and Its Impact on Permanent Establishment: ESS Advertising v. Deputy Director of Income Tax

Date: Aug 21, 2018
Arm's Length Remuneration and Its Impact on Permanent Establishment: ESS Advertising v. Deputy Director of Income Tax Introduction The case of ESS Advertising (Mauritius) SNC et Compagnie v. Deputy...
Clarification on Tax Deduction at Source for Development Fees and Royalties under DTAA: DCIT v. Inzi Control India Limited

Clarification on Tax Deduction at Source for Development Fees and Royalties under DTAA: DCIT v. Inzi Control India Limited

Date: Aug 17, 2018
Clarification on Tax Deduction at Source for Development Fees and Royalties under DTAA: DCIT v. Inzi Control India Limited Introduction The case of DCIT, Chennai v. Inzi Control India Limited...
M/s. OSE Infrastructure Ltd. v. ACIT: Clarifying Penalty Proceedings Under Section 271(1)(c)

M/s. OSE Infrastructure Ltd. v. ACIT: Clarifying Penalty Proceedings Under Section 271(1)(c)

Date: Aug 15, 2018
M/s. OSE Infrastructure Ltd. v. ACIT: Clarifying Penalty Proceedings Under Section 271(1)(c) Introduction The case of M/s. OSE Infrastructure Ltd., Gurgaon v. ACIT, New Delhi (Income Tax Appellate...
Refining Revisionary Review: Torrent Pharmaceuticals Ltd. v. Deputy Commissioner of Income-tax on the Scope of Section 263 and Its Limitations

Refining Revisionary Review: Torrent Pharmaceuticals Ltd. v. Deputy Commissioner of Income-tax on the Scope of Section 263 and Its Limitations

Date: Aug 9, 2018
Refining Revisionary Review: Torrent Pharmaceuticals Ltd. v. Deputy Commissioner of Income-tax on the Scope of Section 263 and Its Limitations Introduction The case of Torrent Pharmaceuticals Ltd. v....
Allotment of Shares in Settlement of Pre-existing Liabilities Not Subject to Section 68 of Income Tax Act: V.R. Global Energy v. IT Officer

Allotment of Shares in Settlement of Pre-existing Liabilities Not Subject to Section 68 of Income Tax Act: V.R. Global Energy v. IT Officer

Date: Aug 7, 2018
Allotment of Shares in Settlement of Pre-existing Liabilities Not Subject to Section 68 of Income Tax Act V. R. Global Energy (P.) Ltd. v. Income-tax Officer, Corporate Ward 3(4), Chennai Court:...
Jurisdictional Oversight in Income Tax Tribunal: Smt. B. Jayalakshmi v. Assistant Commissioner of Income-tax

Jurisdictional Oversight in Income Tax Tribunal: Smt. B. Jayalakshmi v. Assistant Commissioner of Income-tax

Date: Jul 31, 2018
Jurisdictional Oversight in Income Tax Tribunal: Smt. B. Jayalakshmi v. Assistant Commissioner of Income-tax Introduction The case of Smt. B. Jayalakshmi v. Assistant Commissioner of Income-tax,...
ITA Navneet Agarwal vs ITO: Upholding the Principle of Evidentiary Support in Long Term Capital Gains Exemptions

ITA Navneet Agarwal vs ITO: Upholding the Principle of Evidentiary Support in Long Term Capital Gains Exemptions

Date: Jul 21, 2018
ITA Navneet Agarwal vs ITO: Upholding the Principle of Evidentiary Support in Long Term Capital Gains Exemptions Introduction The case of Navneet Agarwal, Legal Heir of Late Kiran Agarwal, Kolkata v....
Autodesk India v. Deputy Commissioner of Income Tax: Establishing Turnover Filters in Transfer Pricing ALP Determination

Autodesk India v. Deputy Commissioner of Income Tax: Establishing Turnover Filters in Transfer Pricing ALP Determination

Date: Jul 7, 2018
Autodesk India v. Deputy Commissioner of Income Tax: Establishing Turnover Filters in Transfer Pricing ALP Determination Introduction The case of Autodesk India (P.) Ltd. v. Deputy Commissioner of...
Disallowance of Deduction for Belated Payment of Employees' Contributions under EPF & ESI Acts

Disallowance of Deduction for Belated Payment of Employees' Contributions under EPF & ESI Acts

Date: Jul 3, 2018
Disallowance of Deduction for Belated Payment of Employees' Contributions under EPF & ESI Acts Introduction In the case of Popular Vehicles & Services (P.) Ltd. v. Commissioner of Income-tax,...
Clarification on Section 153C of Income Tax Act: Assessment Period Post-Search – M/s. BNB Investment & Properties Ltd. v. DCIT

Clarification on Section 153C of Income Tax Act: Assessment Period Post-Search – M/s. BNB Investment & Properties Ltd. v. DCIT

Date: Jun 28, 2018
Clarification on Section 153C of Income Tax Act: Assessment Period Post-Search Introduction In the landmark case of M/s. BNB Investment & Properties Ltd., Gurgaon v. DCIT, Faridabad, decided by the...
ACIT v. Late Shri Bholidas T. Patel: Reinforcement of Section 50C's Applicability Based on Incriminating Material

ACIT v. Late Shri Bholidas T. Patel: Reinforcement of Section 50C's Applicability Based on Incriminating Material

Date: Jun 20, 2018
ACIT v. Late Shri Bholidas T. Patel: Reinforcement of Section 50C's Applicability Based on Incriminating Material Introduction The case ACIT, Central Circle-1(2), Ahmedabad v. Late Shri Bholidas T....
Clarifying the Scope of Section 263: Adequacy of Assessing Officer's Inquiry in Commissioner’s Revision - Commissioner of Income Tax v. Kamal Galani

Clarifying the Scope of Section 263: Adequacy of Assessing Officer's Inquiry in Commissioner’s Revision - Commissioner of Income Tax v. Kamal Galani

Date: Jun 12, 2018
Clarifying the Scope of Section 263: Adequacy of Assessing Officer's Inquiry in Commissioner’s Revision 1. Introduction The case of Commissioner of Income Tax v. Kamal Galani adjudicated by the...
Establishing the Necessity of Incriminating Material for Additions under Section 153A: Insights from ACIT Circle 2(1), Gwalior v. M/s Gahoil Dal & Oil Mills Pvt. Ltd.

Establishing the Necessity of Incriminating Material for Additions under Section 153A: Insights from ACIT Circle 2(1), Gwalior v. M/s Gahoil Dal & Oil Mills Pvt. Ltd.

Date: Jun 9, 2018
Establishing the Necessity of Incriminating Material for Additions under Section 153A: Insights from ACIT Circle 2(1), Gwalior v. M/s Gahoil Dal & Oil Mills Pvt. Ltd. Introduction The case of ACIT...
ITA Validates Appeal: Jurisdiction under Section 153A Requires Incriminating Material Found During Search

ITA Validates Appeal: Jurisdiction under Section 153A Requires Incriminating Material Found During Search

Date: Jun 8, 2018
ITA Validates Appeal: Jurisdiction under Section 153A Requires Incriminating Material Found During Search Introduction In the landmark case of Moon Beverages Ltd., New Delhi v. ACIT, Central...
APAT Reinforces Arm's Length Principle: Denies Aggregated TNMM for Discrete International Transactions in Knorr Bremse India v. ACIT

APAT Reinforces Arm's Length Principle: Denies Aggregated TNMM for Discrete International Transactions in Knorr Bremse India v. ACIT

Date: Jun 1, 2018
APAT Reinforces Arm's Length Principle: Denies Aggregated TNMM for Discrete International Transactions in Knorr Bremse India v. ACIT Introduction The case of Knorr Bremse India Pvt. Ltd., Faridabad...
Non-Retrospective Applicability of Section 234E: Insights from State Bank of India v. CIT A, Gwalior

Non-Retrospective Applicability of Section 234E: Insights from State Bank of India v. CIT A, Gwalior

Date: Jun 1, 2018
Non-Retrospective Applicability of Section 234E: Insights from State Bank of India v. CIT A, Gwalior Introduction The case of State Bank of India, Gwalior v. Commissioner of Income Tax (Appeals),...
M/s. Dharampal Satyapal Ltd. v. DCIT: Necessity of Incriminating Material for Section 153A Assessments

M/s. Dharampal Satyapal Ltd. v. DCIT: Necessity of Incriminating Material for Section 153A Assessments

Date: May 18, 2018
M/s. Dharampal Satyapal Ltd. v. DCIT: Necessity of Incriminating Material for Section 153A Assessments Introduction The case of M/s. Dharampal Satyapal Ltd., Delhi v. DCIT, New Delhi was adjudicated...
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