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Showing 1 to 20 of 1750 Records Search Text: Ip support services india pvt ltd |
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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 invocation of Section 14A is automatic and comes into operation as soon as the dividend income is claimed exempt. See Maxopp Investment Ltd. & Others Versus Commissioner of Income Tax [2011 (11) TMI 267 - Delhi High Court] wherin held the prescribed method being the method stipulated in rule 8D of the s... ... ...
2012 (10) TMI 1068 - ITAT DELHI The Tribunal upheld the first appellate order, dismissing the revenue's challenge regarding the deletion of Rs. 50,29,506/- for repair and maintenance expenses. The Tribunal found no fault in the decision and rejected the appeal, citing previous Tribunal decisions in favor of the assessee for the assessment year 2006-07. The order was issued on 26th October 2012.
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 - Held that:- There is no dispute that part of the income of the assessee from its business is from dividend which is exempt from tax whereas the assessee was unable to produce any material before the authorities below showing the source from which such shares were acquired the mere fact that those ... ... ...
2012 (3) TMI 488 - ITAT DELHI The Tribunal dismissed the Department's appeal for the assessment year 2007-08, upholding the CIT(A)'s decision to delete certain additions challenged by the Department. The Tribunal found that the expenses for repair and maintenance, depreciation, and investment-related expenses were correctly accounted for and offered for taxation, based on a previous order in the assessee's own case. Consequently, the Tribunal upheld the CIT(A)'s order in its entirety, ruling against the Department's contentions.
2014 (2) TMI 465 - ITAT DELHI Disallowance of repair and maintenance expenses - excess depreciation on furniture and fixture and plant & machinery – Held that:- The decision in IP Support Services (India) Pvt. Ltd. Versus DCIT (OSD) CIT-IV, New Delhi [2012 (9) TMI 364 - ITAT DELHI] followed - There is no error whatsoever in the order of the Ld. CIT (A) - there was no separate claim of repair and maintenance and depreciation by the assessee - The reimbursement and 25% mark up had already been offered by the assessee to tax - ... ... ...
2016 (11) TMI 357 - ITAT MUMBAI Depreciation claim - capital expenditure being technical fee and other expenses, incurred towards setting up of the Hotel project - Held that:- Tribunal decided this issue in A.Ys. 2007-08 in favour of the assessee and held that assessee was entitled to capitalise the amount and claim depreciation thereon. But for the purpose of verification of facts, this issue was sent back to the file of the AO with the direction to verify the amount of expenditure and allowing depreciation accordingly. Thus,... ... ...
2020 (11) TMI 50 - ITAT DELHI Disallowance u/s 36 (1)(iii) - interest paid on the loan - HELD THAT:- Loans taken were utilised for advancing the loans in furtherance of their business and, therefore, the assessee is entitled to claim that the difference between the interest paid and interest received alone has to be considered towards the claim of interest expenditure and any disallowance of the interest expense has to be made only with reference to the difference amount and not with reference to the entire interest amount p... ... ...
2019 (10) TMI 723 - ITAT DELHI Disallowance u/s 14A - mandation of recording proper satisfaction by AO - HELD THAT:- The Hon ble Punjab Haryana High Court in the case of Abhishek Industries Ltd., [ 2015 (2) TMI 672 - PUNJAB AND HARYANA HIGH COURT] held that onus upon A.O. to record satisfaction that interest bearing funds used for investment to earn tax free income . The assessee in the present case has claimed that receipt of dividend income does not involve any expenditure since the dividend is directly credited through ECS... ... ...
2020 (1) TMI 1290 - ITAT CHENNAI Allowing ESOP expenditure as revenue expenditure - HELD THAT:- The issue in the present appeal is squarely covered in favour of the assessee in the case of Lemon Tree Hotel [ 2015 (11) TMI 404 - DELHI HIGH COURT] and case of PVP Ventures Ltd.[ 2012 (7) TMI 696 - MADRAS HIGH COURT] confirmed by SC [ 2014 (3) TMI 1127 - SC ORDER] - CIT(A) has not erred to direct the AO to allow the ESOP expenses. Depreciation on technical know-how holding it to be intangible assets - HELD THAT:- This issue was sub... ... ...
2024 (9) TMI 1631 - DELHI HIGH COURT Validity of reassessment proceedings against non-existent entities/ amalgamanting compnaies - Reassessment action initiated by the respondents on the ground of the amalgamated entity having never been placed on notice - as argued no notices were served upon the amalgamated entity and orders of assessment as well as notices of reassessment were maintained in the name of the amalgamating entity - HELD THAT:- Position in law appears to be well- settled that a notice or proceedings drawn against a d... ... ...
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 well as the provisions of the Aadhaar Act do not create a surveillance state. This is ensured by the manner in which the Aadhaar project operates. During the enrollment process, minimal biometric data in the form of iris and fingerprints is collected. The Authority does not collect purpose, location or... ... ...
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 advertisers in India under the Google AdWords Reseller Agreement ? - ‘lndia-lreland Treaty - right to use of Trademark - TDS u/s 195 - Held that:- Considering the AdWord Distributor Agreement and the Service Agreement together and we find that under these agreements assessee was licenced to use the trad... ... ...
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 and automated services - royalty and fee for technical/included services ( FTS/FIS ) - India-USA DTAA - assessee argued that appellant merely provides standard and automated cloud computing services to its customers which do not make available technical knowledge, know how, skill, experience, etc., to ... ... ...
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 under Section 244A(1) - HELD THAT:- We observe that the interest on refund either it can be directly given by the Department to the assessee or as in the present case, suppose if some tax liability is arising with regard to the assessee in respect of the earlier years then the interest on the refund amoun... ... ...
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 the Act. See M/S. BAJAJ ALLIANZ GENERAL INSURANCE COMPANY LTD. [ 2019 (8) TMI 370 - ITAT PUNE] TP Adjustment - comparable selection - HELD THAT:- Assessee company is engaged in the business of Software Development, Consultancy Services, and Technical Support Services, thus companies functionally dissim... ... ...
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 delete the addition made towards AMP expenses. Disallowance of Seminars, Conventions and sales promotion expenses - expenses incurred related to doctors in the form of seminars and conventions and sales promotion - HELD THAT:- Similar issue came for consideration before this Tribunal in the case of Astra ... ... ...
2019 (10) TMI 1310 - ITAT DELHI TP Adjustment - comparable selection - Functional dissimilarity - HELD THAT:- Assessee is providing Information Technology Enabled Services (ITES) to its AEs, selected itself as the tested party and applied Transactional Net Margin Method (TNMM) as the Most Appropriate Method (MAM) with OP/OC as Profit Level Indicator (PLI). Acropetal being engaged in development of products and intellectual property, having no segmental profitability available and has undergone business restructuring, extra-ord... ... ...
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 the fact that there is no transfer of any intellectual property, or any exclusive right has been granted to the assessee for using such intellectual property. Rather, the payment is made by the assessee to J P Coats, based on the agreement between BT to J P Coats. The assessee has made the payment bas... ... ...
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 goods manufactured by its foreign controlling parent and did not own any trademark or brand, had performed significant functions like brand development, market development, marketing customer support, technical and administrative support on behalf of its AEs in India bearing cost, investing huge sum a... ... ...
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) - held that:- In satellite transmission, a particular frequency is assigned to the customer and in cable transmission, the customer gets a dedicated bandwidth. This is different from the use of a standard facility like the telephone at our homes. A broadband can be divided into two major categories... ... ...
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