Vocational Training as ‘Education’ under Section 2(15): Karnataka HC Allows Section 11 Exemption Despite Surplus | Deshpande Education Trust v. ACIT (2025)

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My Tax Expert
27/12/2025  |  0 COMMENTS  |  VISITOR'S COUNT: 635
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Vocational training for rural youth qualifies as ‘education’ under section 2(15); Surplus generation no bar to exemption under section 11. The appellant is a registered trust under Section 12AA of the Act engaged in...

Eligibility of Partner’s Remuneration for Presumptive Taxation u/s 44ADA: ITAT Delhi Allows 44ADA Benefit to Chartered Accountant Partner | Ranu Gupta vs ACIT (2025)

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CA DR VINAY MITTAL
26/12/2025  |  0 COMMENTS  |  VISITOR'S COUNT: 2501
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The appeal before the ITAT Delhi (SMC Bench) in the case of Sh. Ranu Gupta vs ACIT, National e-Assessment Centre, Delhi for AY 2018-19 concerns the applicability of Section 44ADA to remuneration received by a Chartered A...

Reopening Notice by Jurisdictional AO Instead of Faceless AO Quashed: Rahul Bagrecha v. DCIT (2025) | Invalid Section 148 Notice & Assessment Under Faceless Regime

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My Tax Expert
25/12/2025  |  0 COMMENTS  |  VISITOR'S COUNT: 642
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Reopening notice issued by Jurisdictional Assessing Officer (JAO) instead of Faceless Assessing Officer (FAO) was to be quashed. The Jurisdicational Assessing Officer issued reopening notice dated 24.03.2024 to the asses...

Sales Discount to Stockists Not Commission – No TDS u/s 194H: Mumbai ITAT in Novartis Healthcare (P) Ltd. v. DCIT (TDS) Following Piramal Healthcare (Bom HC)

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My Tax Expert
24/12/2025  |  0 COMMENTS  |  VISITOR'S COUNT: 307
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Sales discount to stockists/wholesalers, not commission, not liable to TDS under section 194H Mumbai ITAT holds that the transaction between the Assessee (Novartis Healthcare (P) Ltd. - A pharmaceutical trading company)...

Non-Compete Fee: Revenue or Capital Expenditure? Supreme Court in Sharp Business System (India) Pvt. Ltd. v. CIT (2025) on Section 37(1), Enduring Benefit Test & Depreciation u/s 32(1)(ii)

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CA. Ajay Kumar agarwal
24/12/2025  |  0 COMMENTS  |  VISITOR'S COUNT: 335
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Nature of Expenditure – Non-Compete FeeCapital or Revenue | Allowability of Depreciation under Section 32(1)(ii) Sharp Business System (India) Pvt. Ltd. v. Commissioner of Income TaxSupreme Court | Civil Appea...

Levy of Late Filing Fee under Section 234E for TDS Statements:

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CA. Ajay Kumar agarwal
23/12/2025  |  0 COMMENTS  |  VISITOR'S COUNT: 794
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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)

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My Tax Expert
23/12/2025  |  0 COMMENTS  |  VISITOR'S COUNT: 250
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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)

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My Tax Expert
23/12/2025  |  0 COMMENTS  |  VISITOR'S COUNT: 224
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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

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My Tax Expert
22/12/2025  |  0 COMMENTS  |  VISITOR'S COUNT: 222
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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

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My Tax Expert
22/12/2025  |  0 COMMENTS  |  VISITOR'S COUNT: 260
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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...