Income Tax Appellate Tribunal Case Commentaries

Clarification on Section 14A Applicability in Disallowing Interest Expenses - Commissioner of Income-tax v. Lakhani Marketing Inc.

Date: Apr 3, 2014

Clarification on Section 14A Applicability in Disallowing Interest Expenses Commissioner of Income-tax, Faridabad v. Lakhani Marketing Inc. Court: Income Tax Appellate Tribunal Date: April 2, 2014...

Four Soft Pvt. Limited v. DCIT: Critical Insights into Transfer Pricing Compliance and Expenditure Characterization under Indian Income Tax Law

Date: Mar 29, 2014

Four Soft Pvt. Limited v. DCIT: Critical Insights into Transfer Pricing Compliance and Expenditure Characterization under Indian Income Tax Law Introduction In the landmark case of Four Soft Pvt....

Transponder Fees and Royalty Classification: Analysis of Viacom 18 Media v. ADIT

Date: Mar 29, 2014

Transponder Fees and Royalty Classification: Analysis of Viacom 18 Media v. ADIT Introduction The case of Viacom 18 Media (P.) Ltd. v. Assistant Director of Income-tax (International Taxation) -2(2),...

Jm Financial Limited v. CIT: Tribunal Sets Precedent on Section 14A Disallowance for Strategic Investments

Date: Mar 27, 2014

Jm Financial Limited v. CIT: Tribunal Sets Precedent on Section 14A Disallowance for Strategic Investments Introduction The case of Jm Financial Limited v. Commissioner of Income Tax (Appeals)...

Benami Transactions and Income Estimation: Landmark Ruling in Faridabad Tax Appellate Tribunal

Date: Mar 15, 2014

Benami Transactions and Income Estimation: Landmark Ruling in Faridabad Tax Appellate Tribunal Introduction The case of Asstt. Commissioner Of Income Tax, Circle-II, B-Block, CGO Complex, NH-IV,...

Defining 'International Transactions' under Section 92B: Comprehensive Analysis of Bharti Airtel Ltd. v. Additional Commissioner of Income-tax

Date: Mar 12, 2014

Defining 'International Transactions' under Section 92B: Comprehensive Analysis of Bharti Airtel Ltd. v. Additional Commissioner of Income-tax Introduction The case of Bharti Airtel Ltd. v....

Comprehensive Commentary on Bharti Airtel Ltd. v. Additional Commissioner of Income-tax: Establishing Revenue Treatment of License Fees, Interest, and ESOPs

Date: Mar 12, 2014

Comprehensive Commentary on Bharti Airtel Ltd. v. Additional Commissioner of Income-tax Introduction The case of Bharti Airtel Ltd. v. Additional Commissioner of Income-tax, Range -2, New Delhi...

Clarifying Comparability in TNMM for ITES Sector: Excluding Abnormally Profitable KPOs in Transfer Pricing

Date: Mar 8, 2014

Clarifying Comparability in TNMM for ITES Sector: Excluding Abnormally Profitable KPOs in Transfer Pricing Introduction The case of Maersk Global Centres (India) Private Limited v. CIT adjudicated by...

Amortization of Premium on HTM Government Securities: Insights from S.K. Dist. Central Co-Op. Bank Ltd. v. CIT

Date: Mar 8, 2014

Amortization of Premium on HTM Government Securities: Insights from S.K. Dist. Central Co-Op. Bank Ltd. v. CIT Introduction The case of S.K. Dist. Central Co-Op. Bank Ltd. v. Commissioner of Income...

ITA Upholds Deletion of Additions Under Sections 69C/69 and 2(22)(e) for Lack of Specific Evidence

Date: Mar 6, 2014

ITA Upholds Deletion of Additions Under Sections 69C/69 and 2(22)(e) for Lack of Specific Evidence Introduction The case of Shri Shiv Shankar Lal Gupta v. The ACIT Central Circle-1 Jaipur adjudicated...

Principle of Mutuality and Tax Liability: International Hotel Licensing Co. v. Dit

Date: Mar 6, 2014

Principle of Mutuality and Tax Liability: International Hotel Licensing Co. v. Dit Introduction The case International Hotel Licensing Company v. Dit adjudicated by the Income Tax Appellate Tribunal...

Reaffirmation of Section 263 Jurisdiction: Personal Examination Required by CIT

Date: Mar 1, 2014

Reaffirmation of Section 263 Jurisdiction: Personal Examination Required by CIT Introduction The case of Dharmendra Kumar Bansal v. Commissioner of Income-tax adjudicated by the Income Tax Appellate...

Distinguishing Co-operative Societies from Co-operative Banks Under Section 80P: Tararani Mahila Co-op. Credit Society Ltd. Ruling

Date: Mar 1, 2014

Distinguishing Co-operative Societies from Co-operative Banks Under Section 80P: Tararani Mahila Co-op. Credit Society Ltd. Ruling Introduction The case of Tararani Mahila Co-op. Credit Society Ltd....

Removal of the Eight-Year Limit on Carry Forward of Unabsorbed Depreciation under Section 32(2)

Date: Feb 25, 2014

Removal of the Eight-Year Limit on Carry Forward of Unabsorbed Depreciation under Section 32(2) Introduction The case of Commissioner of Income-tax v. Gujarat Themis Biosyn Ltd. adjudicated by the...

Limits of Section 80P Exemption for Co-operative Societies: Analysis of Tumkur Merchants Souharda Credit Co-Operative Ltd. v. Ito

Date: Feb 22, 2014

Limits of Section 80P Exemption for Co-operative Societies: Analysis of Tumkur Merchants Souharda Credit Co-Operative Ltd. v. Ito 1. Introduction The case of Tumkur Merchants Souharda Credit...

Hyundai Motors India Engineering P. Ltd. v. ITO: Advancing Transfer Pricing Standards on Comparability and Filter Applications

Date: Feb 22, 2014

Hyundai Motors India Engineering P. Ltd. v. ITO: Advancing Transfer Pricing Standards on Comparability and Filter Applications Introduction The case of Hyundai Motors India Engineering P. Ltd. v....

OnMobile Global Ltd. v. Additional Commissioner of Income-tax: Defining Revenue Expenditures and Asset Classification for Tax Deductions in IT Services

Date: Feb 22, 2014

OnMobile Global Ltd. v. Additional Commissioner of Income-tax: Defining Revenue Expenditures and Asset Classification for Tax Deductions in IT Services Introduction The case of OnMobile Global Ltd....

Ito v. Divyajyothi Credit Co-Operative Society Ltd.: Clarifying Eligibility for Section 80P Deductions

Date: Feb 8, 2014

Ito v. Divyajyothi Credit Co-Operative Society Ltd.: Clarifying Eligibility for Section 80P Deductions Introduction The case of Ito v. Divyajyothi Credit Co-Operative Society Ltd. adjudicated by the...

Eligibility of Section 80IB(10) Deductions Under Section 153A Assessments: A Comprehensive Analysis of Malpani Estates v. Assistant Commissioner of Income-tax

Date: Jan 31, 2014

Eligibility of Section 80IB(10) Deductions Under Section 153A Assessments: A Comprehensive Analysis of Malpani Estates v. Assistant Commissioner of Income-tax Introduction The case of Malpani Estates...

Gurdaspur Improvement Trust v. Deputy Commissioner of Income Tax: Upholding Section 11 Exemptions

Date: Jan 24, 2014

Gurdaspur Improvement Trust v. Deputy Commissioner of Income Tax: Upholding Section 11 Exemptions Introduction The case of Deputy Commissioner Of Income Tax, Circle-Vi, Pathankot v. M/S. Gurdaspur...