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Levy of Late Filing Fee under Section 234E for TDS Statements:
Levy of Late
Filing Fee under Section 234E for TDS Statements:A
Consolidated Judicial Analysis of Pre-1 June 2015 Period**1. Introduction :-The levy of late filing fee under Section
234E of the Income-tax Act, 1961 fo...
Bogus Purchases Addition under Section 69 Unsustainable without Rejection of Books u/s 145(3): Delhi ITAT in KDP Infrastructure (P) Ltd. v. DCIT (AY 2012-13)
Addition for bogus purchases under section 69 unsustainable sans rejection of books of accounts under section 145(3)
Delhi ITAT deletes addition under Section 69 made on account of alleged bogus purchases sans rejection...
Section 263 Revision Unsustainable: Delhi ITAT Quashes CIT Action on Offshore Supplies under Section 44BBB | Shenzhen SDG Information Co. Ltd. v. CIT (ITAT Delhi, AY 2017-18)
Section 263 unsustainable
Delhi ITAT holds that Assessee’s offshore supplies revenue are not taxable in India under the provisions of Section 44BBB; In the extant case, Assessee, a Chinese company engaged in R&D, ...
Liaison Office Activities Held Preparatory & Auxiliary – No PE or Profit Attribution Under India-Netherlands DTAA | Oxbow Energy ITAT Mumbai
The appeal before the Income Tax Appellate Tribunal concerned the determination of whether the activities carried out by the Liaison Office (LO) of the assessee, a foreign company incorporated in the Netherlands, constit...
Cost-to-Cost Reimbursement of Salaries to Seconded Employees Not Taxable as FTS – Delhi ITAT Relies on Boeing India | Toshiba Energy Case
The Delhi ITAT in Toshiba Energy System & Solutions Corporation v. DCIT (International Taxation) held that reimbursement of salaries paid to seconded employees on a cost-to-cost basis without markup is not taxable as...
Accumulation u/s 11(2) Cannot Be Denied for Vague Form 10 If Purpose Aligns With Trust Objects: Mumbai ITAT | Harmony Foundation v. ITO (Exemption) [TS-1673-ITAT-2025]
Accumulation under section 11(2) cannot be denied for vague Form 10 if purpose aligns with Trust’s objectiveMumbai ITAT allows Assessee’s (Trust) appeal and holds that accumulation of income under Section 11(2) canno...
Validity of Reopening of Assessment and Addition under Section 69 without Rejection of Books
Validity of
Reopening of Assessment and Addition under Section 69 without Rejection of
Books M/s KDP
Infrastructure Private Limited v. DCITITAT Delhi |
ITA No. 1094/Del/2024 | Order dated 12 December 2025 1...
Foreign Tax Credit Allowed When Form 67 & Revised Return Filed in Time: Delhi ITAT Grants Relief u/s 90/91, Deletes s.69 & s.115BBE Additions | DCIT v. Malvinder Mohan Singh (ITAT Delhi, 2025)
Directs Assessing Officer to grant relief under section 90/91 as Form No. 67 & revised return filed within stipulated time
The case of the Assessee was taken in Limited Scrutiny on grounds of Double Taxation Relief ...
Section 43CB Mandates Percentage Completion Method for Real Estate Developers: Mumbai ITAT Confirms Additions | Faithfull Developers v. ACIT (ITAT Mumbai, 2025)
Section 43CB percentage completion method mandatory for real estate business; Confirms additions
Mumbai ITAT dismisses Assessee’s appeal observing that the CIT(A) rightly held that the provisions of Section 43CB is ap...
Supreme Court Allows Non-Compete Fee as Revenue Expenditure u/s 37(1); Reverses High Court View, Matters Remanded to ITAT | SC Ruling (19 Dec 2025)
Non-compete fee allowable revenue expense under section 37(1); Reverses High Court ratio
December 19, 2025Supreme Court reverses High Court judgment, holds that non-compete fee payment is allowable revenue expense under...