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Showing 81 to 100 of 1908 Records Search Text: tds delivery order charges |
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2015 (7) TMI 147 - ITAT DELHI Rejection of the books of account of the assessee for the reason that assessee is not maintaining qualitative stock tally - Held that:- It is not disputed that the assessee's yield commensurate to the industrial GP disclosed by the assessee is comparable and satisfactory. In our considered view, when no palpable inconsistency in the books of account they cannot be rejected merely on the basis of assumption that assessee is not producing quantitative tally. Had there been any quantitative tally, ... ... ...
2013 (11) TMI 1695 - ITAT AHMEDABAD The ITAT allowed the assessee's appeals and dismissed the Revenue's appeals, concluding that the disallowances under sections 40A(3) and 40(a)(ia) of the Income Tax Act were not justified. The ITAT held that payments to brokers for hiring trucks fell under an exception in Rule 6DD(k) and that payments to truck owners for hiring trucks did not require TDS deduction under section 194C.
2005 (6) TMI 218 - ITAT CALCUTTA-E Deduction of tax component and salary of expatriate employees - Assessee-in-default - Deduction of interest levied u/s 201(1A) - Operational loss - claimed deduction on account of sum refunded to the Punjab Housing Board (PHB) on account of the investment - difference of opinion between ld members - Third Member Oder - Whether the assessee is entitled to deduction of tax component of salary of expatriate employees relating to assessment years 1990-91 and 1991-92 in assessment year 1995-96 in whi... ... ...
2022 (7) TMI 1210 - ITAT MUMBAI TP Adjustment - ALP determination - assessee claimed that if CUP method is applied for determining the arms length price of international transaction of brokerage and commission earned, downward adjustment to the extent of 50% is required to be granted to the assessee - HELD THAT:- Rule 10 B (1) (a) (ii) of the income tax rules 1962 also allowed adjustment to the prices which could materially affect the price in the open market. Further guidelines (2022) at paragraph number 2.17 also suggest tha... ... ...
2021 (8) TMI 583 - ITAT KOLKATA TDS u/s 194C - Addition u/s 40(a)(i) on account of payment made to International Freight Forwarding Agents - HELD THAT:- As decided in own case [ 2019 (4) TMI 2000 - ITAT KOLKATA] expenses/payments were in the nature of reimbursement with no element of income chargeable to tax in India or no part of such payment was made towards carrying on any work by the parties /vendors and, therefore, taxes need not to be withheld by assessee on such payments - Decided against revenue.... ... ...
2019 (7) TMI 125 - ITAT AHMEDABAD Disallowance of expenditure incurred towards village development - expenditures were in the nature of donation or in the nature of gratuitous payments not incurred for business exigency - CIT(A) has deleted following earlier year orders - HELD THAT:- In order to earn goodwill of the people residing in the neighbor-hood area and to keep social relations with residents, assessee company has to incur certain expenditure, which would ultimately facilitate the assessee s business, otherwise there wou... ... ...
FINANCE BILL, 2018 PROVISIONS RELATING TO DIRECT TAXES The Finance Bill, 2018 introduces amendments to the Income-tax Act, 1961, focusing on enhancing tax base, reducing corporate tax for SMEs, and promoting equity in personal income tax. Key changes include maintaining income tax rates from 2017-18, imposing surcharges on higher incomes, and introducing a new Health and Education Cess. The Bill proposes mandatory PAN for entities with transactions over 2.5 lakh, expands the definition of "accumulated profits," and introduces a 10% tax on long-term capital gains exceeding 1 lakh. It also provides deductions for senior citizens and incentives for startups and employment generation. Additionally, it aligns domestic tax laws with international standards for business taxation and facilitates insolvency resolution.
Memorandum Explaining the Provisions in The Finance Bill, 2018 The Finance Bill, 2018 introduces amendments to the Income-tax Act, 1961, focusing on widening the tax base and reducing corporate tax rates for small enterprises. Key changes include revised income tax rates, surcharges, and cess for various entities. The Bill proposes a 10% tax on long-term capital gains from equity exceeding Rs. 1 lakh and introduces Health and Education Cess. It also aims to facilitate insolvency resolution and improve tax administration. Tax incentives are provided for startups, senior citizens, and farm producer companies. The Bill also proposes measures to prevent tax evasion and align domestic tax laws with international standards.
FICCI PRE-BUDGET MEMORANDUM 2018-2019 A pre-budget memorandum by FICCI for 2018-2019 highlights various economic and sectoral issues, emphasizing the need for tax reforms to stimulate growth. Key recommendations include reducing corporate tax rates to 25% for all companies, addressing the inverted duty structure in manufacturing, and expanding GST to include petroleum products. The memorandum advocates for rationalizing GST compliance, enhancing tax incentives for sectors like healthcare and housing, and improving the ease of doing business. It also calls for clarity on tax provisions affecting sectors such as IT, telecommunications, and financial services, and suggests measures to support MSMEs and infrastructure development.
2016 (9) TMI 16 - ITAT DELHI Income attributed to the offshore supply - Existence of PE in India - Held that:- Section 9(1)(i) of the Act provides that income shall be deemed to accrue or arise in India if such income has accrued or arisen through or from a business connection in India. Further, Explanation 1 to section 9(1)(i) of the Act provides that where a business, of which all the operations are not carried out in India, the income of the business deemed to accrue or arise in India shall be only such part of the incom... ... ...
2016 (5) TMI 1500 - ITAT MUMBAI TDS u/s 194C OR 194J - payment made by the assessee on account of data storage charges, processing charges, call centre operation and business services - default u/s 201(1) - DR argued that that since these services involved special managerial skills to carry out the work in specialised manner - HELD THAT:- CIT(A) after having examined and perused agreements with the service providers and after going into the various services provided reached a conclusion that the outsourced services do not requ... ... ...
2016 (5) TMI 1254 - ITAT MUMBAI TDS u/s 194J OR 194C - nature of services received by the assessee by incurring data storage expenses - Held that:- CIT(A) after having examined and perused agreements with the service providers and after going into the various services provided reached a conclusion that the outsourced services do not require any kind of technical and professional expertise and are just simple and repetitive nature of work such as document storage, documents delivery and collection services and documents managem... ... ...
2015 (8) TMI 1500 - ITAT CHENNAI Eligible deduction u/s.10B - whether expenditure incurred in foreign exchange towards telecommunication expenditure and travel expenditure deducted from export turnover should also be deducted from total turnover for arriving at the eligible deduction ? - HELD THAT:- Issue is squarely covered by the decision of the Tribunal in the assessee s own case [ 2011 (10) TMI 619 - ITAT CHENNAI] and case of ITO Vs. Sak soft Ltd. [ 2009 (3) TMI 243 - ITAT MADRAS-D] wherein it was held that such expenditure... ... ...
2015 (9) TMI 280 - ITAT CHENNAI Eligibility for deduction U/s.10B - whether expenditure incurred in foreign exchange towards telecommunication expenditure and travel expenditure deducted from export turnover should also be deducted from total turnover for arriving at the eligible deduction U/s.10B - Held that:- As held in ITO Vs. Sak soft Ltd. [2009 (3) TMI 243 - ITAT MADRAS-D] expenditure incurred towards freight charges and insurance premium in foreign exchange ought to be excluded from both export turnover as well as from t... ... ...
2011 (4) TMI 882 - ITAT, Chennai Applicability of Section 194 on "discount" given by the assessee, a cellular operator to the distributors in the course of selling Sim Cards and Recharge coupons under prepaid scheme against advance payment received from the distributors - Held that:- Transaction between the assessee, a cellular operator, and the prepaid market associates (PMAs) appointed by it whereby SIM cards/recharge coupons are ultimately sold to the subscribers through the latter does not amount to 'sale' of goods and, the... ... ...
2006 (3) TMI 236 - ITAT HYDERABAD-B Deduction of Tax At Source - income deemed to accrue or arise in India on the contracts - non-resident - PE in India or not - contracts are simple sale contracts and or works contracts - Whether section 195 is applicable to the facts of the case in view of the complexity and multiplicity of agreements between various parties on terms of payment - HELD THAT:- The fact that the contract is arranged in accordance with the loan agreement between the Government of India and the Overseas Economic Co-o... ... ...
2025 (2) TMI 1033 - ITAT HYDERABAD Disallowance of finance charges made u/s 36(1)(iii) - as per AO interest bearing funds have been diverted to non-business purpose - HELD THAT:- Basic business of the assessee is real estate development, and in that process, the assessee collected advances from customers for sale of flats. As per the agreement with the customers, the assessee has paid interest in case of delay in delivery of flats. The assessee had also proved that the funds received from the customers in the form of advances hav... ... ...
2023 (10) TMI 845 - ITAT MUMBAI TP Adjustment - payment of technical knowhow fees - benchmarking of the transaction - HELD THAT:- As assessee substantiated that for carrying out business of the assessee, and as assessee is part of MNE, which is providing such services worldwide, to remain in sync with that, the assessee would have needed the identical platform, structure. The services provided by the associated enterprises are supported with the agreement wherein the identified obligations and rights of the parties are crystal... ... ...
2022 (1) TMI 1074 - NATIONAL COMPANY LAW TRIBUNAL , AHMEDABAD BENCH Sanction of scheme of amalgamation - Sections 230-232 of the Companies Act, 2013 - HELD THAT:- On perusal of the Scheme and the proceedings, it appears that the requirements of the provisions of section 230 and 232 are satisfied by the petitioner companies. The proposed Scheme of Amalgamation is bona fide and in the interest of the shareholders and creditors. Petition is allowed - The Scheme envisaging amalgamation of Perlcon Premix Private Limited, the Petitioner Transferor Company with Amol Mi... ... ...
2018 (10) TMI 1974 - ITAT MUMBAI Validity of issuance of notice u/s 148 - basic conditions enshrined in section 147 are not complied with - HELD THAT:- Even in the reasons recorded by the Ld. Assessing Officer, neither he recorded any satisfaction nor made any allegations to the effect that there was a failure on the part of the assessee to disclose the material facts fully and truly. Thus, it can be concluded that so far as Assessment Year 2007-08 and 2008-09 are concerned, the reassessment proceedings are beyond four years (a... ... ...
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