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2016 (1) TMI 582 - DELHI HIGH COURT
Carry forward accumulated business losses - change in shareholding - Held that:- As there was indeed a change of ownership of 100% shares of Yum India from Yum Asia to Yum Singapore, both of which wer... ...
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2022 (10) TMI 256 - ITAT DELHI
TDS u/s 194I OR 194C - deductibility of the tax on the entire payment as rent or to be segregated into rent and CAM - HELD THAT:- While the lease rentals are paid based on a fixed percentage on the n... ...
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2020 (12) TMI 517 - DELHI HIGH COURT
TP Adjustment - ITAT has remanded the matter back to TPO and directed it to consider the combined effect of 14 factors for determining the cost/ value of international transactions in accordance wi... ...
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2018 (10) TMI 1615 - NATIONAL ANTI-PROFITEERING AUTHORITY
Profiteering - restaurant service - benefit of reduction of tax from 18% to 5% not passed to customers - it was also alleged that Respondent was illegally profiteering by appropriating the amount of r... ...
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2018 (2) TMI 1701 - ITAT DELHI
Disallowance of lease rent - Held that:- CIT has allowed the assessee a deduction of ₹ 2,40,000/- per annum for both the years under consideration and has disallowed the remaining amount i.e. &#... ...
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2014 (12) TMI 600 - ITAT DELHI
Transfer pricing adjustment - Disallowance of excessive AMP expenses - Advertisement Marketing and Sales Promotion - assessee has a license arrangement with YRAPL for operation of various KFC and PH o... ...
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2015 (4) TMI 698 - MADRAS HIGH COURT
Whether the goods purchased by the petitioner for carrying on its business activities, are eligible for issuance of C Forms and whether it has to be appreciated by the authority concerned by examining... ...
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2005 (5) TMI 55 - DELHI High Court
Issuance of direction of special audit - Whether the maxim audi alteram partem, if at all and to what extent is applicable to the proceedings before the Assessing Officer while passing a direction as ... ...
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2023 (10) TMI 270 - ITAT DELHI
TDS u/s 194C or 194I - tax liability on CAM charges - short deduction of TDS - Demand u/s. 201(1A) holding the Assessee to be 'Assessee in default' - HELD THAT:- By respectfully following ... ...
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2023 (2) TMI 58 - ITAT DELHI
TDS u/s 194C or 194I - account of CAM charges - Commissioner affirmed the action of the AO in holding that CAM charges paid by the Assessee are part of rent, liable for TDS u/s 194-I however, held th... ...
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2022 (2) TMI 1325 - ITAT DELHI
Carry forward and set off of losses in the case of certain companies - set off of brought forward losses u/s 79 on the ground that there has been change in the shareholding - CIT-A after noting the s... ...
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2015 (9) TMI 138 - ITAT DELHI
Addition on account of advertisement & publicity expenses - CIT(A) deleted the addition - Held that:- As decided in assessee's own case for the assessment years 2001-02 and 2002-03 the expenditure on... ...
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2021 (9) TMI 952 - ITAT MUMBAI
Set off of brought forward losses denied - agreement between the holding company and subsidiary companies - change in the shareholding pattern of the assessee during the assessment year post merger - ... ...
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2023 (3) TMI 850 - ITAT DELHI
TDS u/s 194I/194C - TDS on rent and CAM charge [Common Area Maintenance] - HELD THAT:- As decided in Yum Restaurants India (P.) Ltd [ 2022 (10) TMI 256 - ITAT DELHI] while the lease rentals are paid... ...
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2021 (2) TMI 350 - ITAT DELHI
TP Adjustment - comparable selection - excluding the comparable M/s. 'Cosmic Global Ltd.' in support service segment - HELD THAT:- Since exclusion of the company has been sought first time be... ...
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2018 (7) TMI 2297 - ITAT BANGALORE
TP Adjustment - Incurring of AMP expenditure - whether the TPO was justified in making ALP adjustment in respect of alleged expenditure incurred on AMP functions? - HELD THAT:- The important fact to ... ...
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2023 (3) TMI 101 - ITAT DELHI
TDS u/s 194C OR 194I - deductibility of TDS on rent and CAM - AR has submitted that payment of CAM charges is nothing but reimbursement of common area maintenance expenses incurred by the lessor on g... ...
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2016 (12) TMI 1545 - ITAT MUMBAI
Disallowance of hotel expenses as being not incurred for purpose of business - "wholly and exclusively" - company has incurred hotel expenses for stay of Shri Samyak Veera,NRI, who stayed in India as... ...
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2021 (12) TMI 447 - ITAT MUMBAI
Revision u/s 263 - As per CIT A.O had not deliberated on the provisions of Sec.79 and not conducted any inquiry qua the set-off of the brought forward losses of the previous year against its income f... ...
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2016 (5) TMI 255 - ITAT DELHI
TDS liability - Payment to Association of Tennis Profession (ATP) - disallowance u/s 40(a)(i) - Held that:- Section 194E read with Section 115 BBA apply to payments made to a non-resident sports assoc... ...
