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2015 (10) TMI 752 - DELHI HIGH COURT
Disallowance on account of invoking Rule 8D read with Section 14A - ITAT confirmed CIT(A)order in deleting the disallowance - Held that:- AO has indeed proceeded on the erroneous premise that the invo... ...
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2012 (10) TMI 1068 - ITAT DELHI
SHRI I. C. SUDHIR, JUDICIAL MEMBER AND SHRI A.N. PAHUJA, ACCOUNTANT MEMBER For the Petitioner : : Shri Neeraj Kumar, Sr. For the Respondent : Mr. R. Ganeshan ORDER PER I.C. SUD... ...
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2012 (9) TMI 364 - ITAT DELHI
Disallowance u/s 14A r.w.r. 8D - assessee contested that no interest cost had been incurred by the assessee on any borrowings for the purpose of investment nor any interest was debited to P&L account ... ...
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2012 (3) TMI 488 - ITAT DELHI
SHRI G.D. AGRAWAL, HON BLE VICE PRESIDENT AND SHRI A.D. JAIN, JUDICIAL MEMBER For the Petitioner : Shri Alok Singh, Sr. DR For the Respondent : Shri K.V.S.R. Krishna, CA ORDER ... ...
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2018 (5) TMI 896 - ITAT BANGALORE
Royalty - amount payable towards purchase of advertisement space - whether payment made by the Appellant to Google Ireland Limited in relation to purchase of advertisement space for resale to the adve... ...
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2018 (9) TMI 1733 - Supreme Court
Aadhaar Card - right of Privacy - the main plank of challenge of petitioners is that the Aadhaar project and the Aadhaar Act infringes right to privacy - Held that:- The architecture of Aadhaar as wel... ...
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2022 (11) TMI 1321 - ITAT BANGALORE
Adjustment on account of alleged excessive AMP expenditure - HELD THAT:- As relying in assessee s own case in assessment year [ 2022 (12) TMI 238 - ITAT BANGALORE ] we redirect the Ld.AO/TPO to delet... ...
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2023 (8) TMI 331 - ITAT DELHI
Income deemed to accrue or arise in India - Taxability of cloud service fee received by the assessee from customers in India - payments received by the appellant from Indian customers for standard a... ...
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2020 (3) TMI 244 - ITAT PUNE
Deduction of liability of education cess - HELD THAT:- Education Cess, which is not disallowable item, on its payment, the cess is an allowable expenditure as per provision of section 40(a)(ii) of th... ...
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2022 (5) TMI 1603 - ITAT BANGALORE
Income taxable in India - royalty receipts as assessee has used the process - existence of PE - HELD THAT:- In the present facts of the case the agreement between assessee and J P Coats is clear of... ...
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2020 (3) TMI 575 - ITAT PUNE
TP Adjustment - comparable selection - HELD THAT:- Companies functionally different with that of assessee as engaged in software services need to be deselected as comparable. Interest on refund u... ...
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2021 (3) TMI 1393 - ITAT BANGALORE
TP Adjustment - comparable selection - HELD THAT:- Companies functionally dissimilar with that of assessee captive software development service providers need to be deselected as comparable. Turnover... ...
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2019 (11) TMI 333 - ITAT DELHI
TP Adjustment - Advertising, Marketing and Promotional ( AMP ) Expenses addition - AMP expenditure as international transactions - HELD THAT:- The assessee who is in the business of distribution of g... ...
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2011 (1) TMI 1121 - ITAT CHENNAI
Business connection - Royalty - location of assets and software in India (through the affiliates of the assessee) and rendering of services in India - Deemed to accrue or arise in India - Section 9(1)... ...
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2023 (12) TMI 205 - ITAT BANGALORE
TP Adjustment - comparable selection - HELD THAT:- Following the order of M/s. Sonus Networks India Pvt. Ltd. [ 2020 (10) TMI 663 - ITAT BANGALORE] we direct exclusion of (i) M/s Bodhtree Consulting... ...
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2016 (7) TMI 1318 - ITAT DELHI
TPA - selection of comparable - Held that:- The assessee has been operating in India through a Branch office and is in the business of development of computer software. The software developed by the b... ...
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2016 (8) TMI 727 - ITAT HYDERABAD
Transfer pricing - Valuation of an intangible asset - revenues generated out of the Intellectual Property (“IP”) or not. - Held that:- What is important is the value available at the time of making bu... ...
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2018 (2) TMI 1783 - ITAT DELHI
Depreciation on computer peripherals, assessee claimed depreciation on the equipment like UPS, stabilizer, LAN/WAN, catalyst switches, network switches etc. at 60% - Held that:- We find that the equip... ...
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2017 (10) TMI 1090 - ITAT BANGALORE
Google Adword program functions and work - Royalty payment - Use of Intellectual Property through ITES agreement - amount payable by the Appellant to Google Ireland for the subject assessment years - ... ...
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2015 (10) TMI 485 - ITAT BANGALORE
Interest under Section 234D - Held that:- The charging of interest is consequential and mandatory and the Assessing Officer has no discretion in the matter. This proposition has been upheld by the Hon... ...
