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Showing 1 to 20 of 1908 Records Search Text: tds delivery order charges |
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2017 (1) TMI 266 - ITAT DELHI Enhancing the value of the closing inventory of raw material/ components - Held that:- As decided in assessee own case A Y 2007-08 if valuation of closing stock is changed then the value of opening stock should also be changed on the same basis or method. The closing stock of a particular year is the opening stock of the subsequent year. Not the case of the revenue that the method of valuation of closing stock is materially affecting the accounts and profits disclosed by the assessee. This adjus... ... ...
2013 (8) TMI 57 - ITAT DELHI Assessment pursuant to DRP order - 43 issues. Issues decided in favor of assessee:- Addition of freight inward/ import clearing expenses to cost of closing inventory - Addition on account of cost of rejection of semi finished goods and obsolete items - Addition of provision for increase in price of material to the value of closing inventory - Disallowance of cost of scrap material - Adjustment on account of provision for increase in price of material as prior period expenditure or preponement of... ... ...
2015 (4) TMI 533 - ITAT JAIPUR Unverifiable purchases - assessee is in trading of the precious and semi precious stones - Assessing Officer held that closing stock of assessee had been shown on estimate basis, which partly included cost mentioned in bogus bills also and as such no realistic verification could be possible - CIT(A) confirmed the disallowance made by the Assessing Officer @ 25% on unverifiable purchases - Held that:- The material available on record established that in Jaipur, a rampant practice is in vogue to g... ... ...
2017 (9) TMI 1257 - ITAT DELHI Disallowance of interest expenses incurred on External Commercial Borrowings - Held that:- There is a very thin line of demarcation between the term expansion and extension, which can be differentiated basis the facts and evidences brought on record. Neither the Ld AO or the Ld DRP has brought any evidence on facts to suggest that there was an extension of business during the year under consideration and the interest paid should be disallowed u/s 36(1)(iii) of the Act. Further, the assessee also... ... ...
2015 (3) TMI 490 - ITAT LUCKNOW Transportation charges paid to GAIL - TDS liability u/s 194C or u/s 1941 - CIT(A) deleting the amount of TDS liability determined by the ITO(TDS) u/s 1941 - Held that:- As relying on asseessee s own case [2013 (7) TMI 1 - ITAT LUCKNOW] GAIL has not only supplied/transported the gas sold by it but also the gas purchased by the assessee from other sellers. In those cases the transmission charges paid by the assessee to GAIL certainly attracts the provisions of section 194C of the Act as per circul... ... ...
2021 (9) TMI 1400 - ITAT DELHI Nature of receipts - Credits received by the assessee from International Aero Engines and others, i. e., nature of credits received by the assessee from International Aero Engines - whether the agreement/ transactions are separate or composite? - purpose and nature of credits received by the assessee and their taxability - HELD THAT:- The findings of the learned Commissioner of Income-tax (Appeals), in our opinion, are based on con-jectures and surmises when he wrongly views the agreements with ... ... ...
2023 (1) TMI 65 - ITAT AHMEDABAD Disallowance of deduction u/s. 80-IA - income on sale of certified emission - Reduction by treating the same as capital asset - As per AO the benefit of carbon credit and the activity carried out by the assessee are separate and independent activity. It does not represent any byproduct of the activity carried out by the company - HELD THAT:- We note that there are several orders/ judgments wherein it has been held that the carbon credit received by the assessee represents the capital receipt whi... ... ...
2022 (11) TMI 885 - ITAT AHMEDABAD ITAC reviewed multiple tax assessment issues. Key outcomes include: (1) speculative loss treated as legitimate business expenditure, (2) transaction charges partially allowed, (3) full depreciation granted, (4) debit notes recognized as valid business expenses, (5) interest on advances permitted, and (6) Section 68 cash credit addition deleted. Tribunal predominantly ruled in assessee's favor, emphasizing commercial substance and procedural compliance.
2019 (2) TMI 1198 - ITAT MUMBAI Rejection of books - Held that:- Complete books of account are easily retrievable and accordingly, was drawn on the basis of contemporary records as well as seized material. He explained that bulk of the transactions were undertaken by the assessee through brokerage firms on behalf of the family members and corporate entities promoted by them, all of whom have been assessed by the same AO. It was explained that these entities have placed copies of contract note, bills and others materials during... ... ...
2014 (7) TMI 853 - ITAT MUMBAI Claims of Exemption u/s 10A - Transfer of stock – Held that:- FIFO method has to be applied - the profits for the under valuation is required to be disallowed – CIT (A) observed that the assessee followed the FIFO method on the transfer of 200kgs of gold bars is fair and reasonable and it does not call for any interference - considering the low value plant and machinery worth of only Rs. 16 lakhs, the extent of the electricity consumption noted in the books of accounts, in the absence of any adv... ... ...
2024 (2) TMI 1238 - ITAT RAJKOT TDS u/s 195 - payment for time charter higher charges are Royalty u/s 9(1)(vi) - Non deduction of TDS - CIT(A) held that payments made by the assessee qualified as royalty within the meaning of Section 9(1)(vi) and the assessee was under an obligation to deduct tax at source on such royalty payments - HELD THAT:- The criterion for determining Royalty under the said provision is that the resident should have control and have physical possession over the equipment. The equipment should be under th... ... ...
2019 (4) TMI 1509 - ITAT DELHI Transfer Pricing Adjustment u/s 92CA - payment of model fee - royalty - export commission - operating profit/sales ratio of the assessee @ 12.91% is higher than the average of the operating profit ratio of comparable companies, i.e., (-) 21.97% - TNMM - HELD THAT:- The facts of the present assessment year are identical with that of the [ 2018 (7) TMI 208 - ITAT DELHI] . No distinguishing facts were placed on record by the Ld. DR. The payment of model fee is a consideration in terms of agreement ... ... ...
2019 (3) TMI 1612 - ITAT PUNE Disallowance of Late Delivery Charges - company follows mercantile system of accounting and expenses relating the previous year have been properly provided to arrive the correct profit during the year - HELD THAT:- Late Delivery Fees and pointed out that the issue in earlier year had been decided partly in favour of assessee. The CIT(A) notes that though the assessee had provided details of customer names, invoice number and percentage of Late Delivery Charges but had not provided the copies of ... ... ...
2017 (7) TMI 1076 - RAJASTHAN HIGH COURT TDS u/s 194H and/or 194J - arrangement worked out between the assessee company and the distributor (Agency) - withhold tax at source under S. 194H in respect of sales to its distributors, which are on principal to principal basis and wherein property in the goods is transferred to the distributor - Held that:- Section 194H pre-supposes the payment to be made to the third party namely, Distributor or the Agency and if on a close scrutiny of Section 182, Distributor is not an agent, therefore, in ... ... ...
2015 (12) TMI 1586 - ITAT CHENNAI Assessee’s claim of relief u/s 90 - CIT(A) erred in restricting the assessee’s claim of relief u/s 90 to the extent of tax payable in India on net income i.e difference between interest earned from M/s AHPL and interest paid on borrowings made for advancing the loans to M/s AHPL - Held that:- The provisions of sec. 90 of the Act and clauses of DTAA between India and Singapore clarify that tax credit to the extent of income derived in Singapore and offered to tax in India should be granted. Relie... ... ...
2020 (10) TMI 605 - ITAT BANGALORE Setting off of LOSS OF STPI/SEZ UNITS against business income from non-STPI/non-SEZ units - STPI refers to Software Technology Park and SEZ refers to Special Economic Zone - HELD THAT:- As decided in own case [ 2015 (10) TMI 826 - KARNATAKA HIGH COURT] Loss arising in eligible SEZ/STPI undertakings are not required to be adjusted against the profits arising from other SEZ/STPI undertakings and the said loss can be adjusted against profits arising from non-SEZ/non-STPI units. Accordingly, this is... ... ...
2017 (4) TMI 1092 - ITAT MUMBAI TPA - adjustment in respect of 'Guarantee Commission' and 'Fee for Letter of Undertaking' - Held that:- The details of loans vis-à-vis the security thereof had already been reproduced above. It has also been brought on record that State Bank of India has charged bank guarantee commission to assessee by giving 50% concession on the rate of 1.75% which works out to approximately 0.875%. If various factors and risk involved are evaluated which is quite normal under the foreign guarantee like, count... ... ...
2017 (3) TMI 187 - ITAT MUMBAI Transfer pricing adjustment - corporate guarantee fee adjustment - Held that:- The details of loans vis-à-vis the security thereof had already been reproduced above. It has also been brought on record that State Bank of India has charged bank guarantee commission to assessee by giving 50% concession on the rate of 1.75% which works out to approximately 0.875%. If various factors and risk involved are evaluated which is quite normal under the foreign guarantee like, country risk, currency risk an... ... ...
2016 (11) TMI 1042 - ITAT AMRITSAR Non grant of exemption u/s 11 - Held that:- As all the conditions of section 11 of the Act stand fully satisfied by the assessee cumulatively. Section 12 is not applicable to the facts of the case. Firstly, the income is derived from property held wholly for charitable purposes. Hence, the mandate as per "M. Visvesvaraya Industrial Research and Development Centre" (2012 (11) TMI 235 - BOMBAY HIGH COURT), as to whether the assessee has satisfied the conditions stipulated in section 11 stands comp... ... ...
2012 (11) TMI 1301 - ITAT BANGALORE The Tribunal partly allowed the appeals for A.Y 2006-07 and 2007-08, remanding several issues back to the AO for fresh consideration. Disallowance of expenses related to South Elegant Limited (SEL) was upheld due to lack of original agreements and non-existence of SEL. Various claims under different heads were either disallowed or restricted, with the Tribunal emphasizing the need for verification of details. Remuneration paid to the Managing Director was allowed, while rent received from a sister concern and the applicability of Section 201 were remanded back for further verification.
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