Income Tax Appellate Tribunal Case Commentaries

Reaffirmation of Burden of Proof Principles under Section 68: Commissioner of Income-tax v. Kishori Lal Construction Ltd.

Date: Dec 24, 2009

Reaffirmation of Burden of Proof Principles under Section 68: Commissioner of Income-tax v. Kishori Lal Construction Ltd. Introduction The case of Commissioner of Income-tax, Delhi-II v. Kishori Lal...

Reclassification of Interest Income from Temporary Surplus Funds as Business Income: Insights from Voltas International Ltd. v. Assistant Commissioner of Income-tax

Date: Dec 22, 2009

Reclassification of Interest Income from Temporary Surplus Funds as Business Income: Insights from Voltas International Ltd. v. Assistant Commissioner of Income-tax Introduction Voltas International...

Income Estimation and TDS Non-Deduction: Insights from K. Srinivas Naidu v. Assistant Commissioner of Income Tax

Date: Dec 19, 2009

Income Estimation and TDS Non-Deduction: Insights from K. Srinivas Naidu v. Assistant Commissioner of Income Tax Introduction The case of K. Srinivas Naidu v. Assistant Commissioner of Income Tax...

Recognition of Income for Real Estate Developers: Project Completion Method Upheld in Awadhesh Builders v. Income-tax Officer

Date: Dec 19, 2009

Recognition of Income for Real Estate Developers: Project Completion Method Upheld in Awadhesh Builders v. Income-tax Officer Introduction The case of Awadhesh Builders v. Income-tax Officer...

Export Incentives Not Eligible for Section 80 IB Deduction: Insights from M/S. Liberty India v. CIT(A)

Date: Dec 11, 2009

Export Incentives Not Eligible for Section 80 IB Deduction: Insights from M/S. Liberty India v. CIT(A) Introduction The case of M/S. Liberty India v. Asstt. Commissioner Of Income Tax represents a...

Clarifying the Scope of 'Fees for Technical Services' under Section 194J: Insights from Deputy Commissioner of Income-tax v. Angel Broking Ltd.

Date: Dec 10, 2009

Clarifying the Scope of 'Fees for Technical Services' under Section 194J: Insights from Deputy Commissioner of Income-tax v. Angel Broking Ltd. Introduction The case of Deputy Commissioner of...

Taxation of Excise Duty Refunds and Interest Subsidies: Shree Balaji Alloys v. Income-Tax Officer Establishes Revenue Receipt Classification

Date: Nov 27, 2009

Taxation of Excise Duty Refunds and Interest Subsidies: Shree Balaji Alloys v. Income-Tax Officer Establishes Revenue Receipt Classification Introduction The case of Shree Balaji Alloys v. Income-Tax...

Interpretation of Initial Year and Computation under Section 80-IA(5) of the Income Tax Act: Rangamma Steels & Malleables v. Assistant Commissioner of Income-tax

Date: Nov 14, 2009

Interpretation of Initial Year and Computation under Section 80-IA(5) of the Income Tax Act: Rangamma Steels & Malleables v. Assistant Commissioner of Income-tax Introduction The case of Rangamma...

TNMM Adoption and Proper Adjustment Practices in Transfer Pricing: Insights from IL Jin Electronics v. CIT-A

Date: Nov 7, 2009

Establishing the Transactional Net Margin Method (TNMM) as the Appropriate Transfer Pricing Methodology: A Comprehensive Analysis of IL Jin Electronics (I) (P.) Ltd. v. Assistant Commissioner of...

Interest-Free Loans Between Associated Enterprises: Insights from Perot Systems TSI (India) Ltd. v. Deputy Commissioner of Income-tax

Date: Oct 31, 2009

Interest-Free Loans Between Associated Enterprises: Insights from Perot Systems TSI (India) Ltd. v. Deputy Commissioner of Income-tax 1. Introduction The case of Perot Systems TSI (India) Ltd. v....

Clarifying Deduction Eligibility under Section 80-IA(4): Insights from B.T. Patil & Sons Belgaum Construction v. AC of Income-Tax

Date: Oct 27, 2009

Clarifying Deduction Eligibility under Section 80-IA(4): Insights from B.T. Patil & Sons Belgaum Construction v. AC of Income-Tax Introduction The case of B.T. Patil & Sons Belgaum Construction (P.)...

Strict Interpretation of Section 40(a)(ia) in Income Tax Assessments: Insights from Teja Construction v. Assistant Commissioner of Income-Tax

Date: Oct 24, 2009

Strict Interpretation of Section 40(a)(ia) in Income Tax Assessments: Insights from Teja Construction v. Assistant Commissioner of Income-Tax Introduction The case of Teja Construction v. Assistant...

Determination of Arm's Length Price under TNMM in Deputy Commissioner of Income-tax v. Quark Systems (P.) Ltd.

Date: Oct 23, 2009

Determination of Arm's Length Price under TNMM in Deputy Commissioner of Income-tax v. Quark Systems (P.) Ltd. Introduction The case of Deputy Commissioner of Income-tax v. Quark Systems (P.) Ltd....

Taxation of Foreign Companies under DTAA: Insights from Joint Commissioner of Income-tax vs. State Bank of Mauritius Ltd.

Date: Oct 17, 2009

Taxation of Foreign Companies under DTAA: Insights from Joint Commissioner of Income-tax vs. State Bank of Mauritius Ltd. Introduction The case of Joint Commissioner of Income-tax, Special Range 12...

Indexed Cost of Acquisition for Gifted Assets: Manjula J. Shah Case Analysis

Date: Oct 17, 2009

Indexed Cost of Acquisition for Gifted Assets: Manjula J. Shah Case Analysis Introduction The case of Deputy Commissioner of Income-tax, 12(2) v. Manjula J. Shah adjudicated by the Income Tax...

Kailashnath Malhotra v. Joint Commissioner of Income-tax: Clarifying Rectification under Section 254(2)

Date: Oct 13, 2009

Kailashnath Malhotra v. Joint Commissioner of Income-tax: Clarifying Rectification under Section 254(2) Introduction The case Kailashnath Malhotra v. Joint Commissioner of Income-tax, Special Range...

Spice Communications Ltd. Judgment: Establishing the 25% Allocation for Capital Expenditure in Mixed Expense Cases

Date: Oct 10, 2009

Taxation of Mixed Expenditures: The Spice Communications Ltd. Judgment and Its Impact on Capital vs Revenue Expense Classification Introduction The case of Income-tax Officer, Ward-9(2), New Delhi v....

Defining Charitable Purposes for Regulatory Bodies: A Comprehensive Analysis of Himachal Pradesh EPPCB v. CIT

Date: Aug 29, 2009

Defining Charitable Purposes for Regulatory Bodies: A Comprehensive Analysis of Himachal Pradesh EPPCB v. CIT Introduction The case of Himachal Pradesh Environment Protection and Pollution Control...

Restricting Deductions in Proceedings under Section 153A: Suncity Alloys v. Assistant Commissioner of Income-tax

Date: Aug 20, 2009

Restricting Deductions in Proceedings under Section 153A: Suncity Alloys (P.) Ltd. v. Assistant Commissioner of Income-tax Introduction The case of Suncity Alloys (P.) Ltd. v. Assistant Commissioner...

Mandatory Levy of Interest under Sections 234B and 234C on Income Computed under Section 115JA: Insights from Kanel Oil & Export Inds. Ltd. v. Joint Commissioner of Income-tax

Date: Aug 19, 2009

Mandatory Levy of Interest under Sections 234B and 234C on Income Computed under Section 115JA: Insights from Kanel Oil & Export Inds. Ltd. v. Joint Commissioner of Income-tax Introduction The case...