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Once TDS deducted u/s 194J and income declared u/s 44AD by the matriculation passed assessee, no addition permitted u/s 44ADA
Payment made to non-resident company for providing roaming services cannot be characterized as ‘royalty’
Payment towards research program which would benefit taxpayer in long term should be allowed as deduction u/s 37(1)
Absent service component, sale of software cannot be taxed as FTS
Penalty u/s 43 of Black Money Act is levied for non-reporting of overseas investments and not for making investments from unaccounted money
Routing unaccounted money using listed paper companies, amounts to ‘colorable device’ & fraud on I-T Dept
Reimbursement of cost will be taxable as FTS in absence of evidence of actual cost-allocation & its incurrence
If re-assessment proceedings against partners was dropped on ground of being time barred, protective addition in hands of firm does not survive
Sale of shares cannot be treated as sham in absence of any involvement of taxpayer in price rigging
AMP Expenses incurred for benefit of overseas AE becomes an international transaction and could not result into disallowance u/s 37(1)