Income Tax – Appeal against Tribunal order in Miscellaneous Application, Dependent Agent Permanent Establishment, Substantial questions of law not arising from the impugned order – Appellant (Revenue) filed appeal under Section 260A against the order of the ITAT in a Miscellaneous Application. Respo...
Income Tax – Section 68, Addition in capital account on merger of personal books with proprietorship books, - Respondent, engaged in building and construction, maintained two sets of books, one for proprietorship business and another in personal capacity, and during the year merged personal assets a...
Income Tax – Functional comparability, Exclusion of comparables from the list under TNMM, Inclusion of comparables not forming part of the search matrix, Interest on delayed trade receivables from AEs, Separate benchmarking and rate of interest, Deduction under section 10AA – Foreign exchange gain o...
Income Tax – Interest on Compulsorily Convertible Debentures issued to Associated Enterprise, Arm’s length price, Disallowance of interest under section 94B, Verification of revised computation, Set-off of brought-forward business loss, Penalty under section 270A – Initiation of penalty proceedings...
Income Tax – Rectification under Section 154 – Appellant claimed foreign tax credit in respect of receipts from Nepal, and the case was selected for limited scrutiny on the issue of double taxation relief. The AO called for details and documents, including Form No. 67, and accepted the returned inco...