Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
The ITAT Ahmedabad considered rectification u/s 154 for correct assessment year of DDT. Revenue argued DDT pertained to A.Y. 2014-15, but Section 115-O(3) mandates DDT payment when dividend is declared. DDT must be accounted for in the year it was paid. Assessee rectified Form 3CD for A.Y. 2014-15 and 2015-16 to correct DDT accounting error. CIT(A) rejected revised form, stating it should have been filed before end of relevant assessment year. However, as dividend declaration and DDT payment occurred in A.Y. 2015-16, DDT should be accounted for in A.Y. 2015-16. Assessee's appeal allowed.
The ITAT Ahmedabad considered rectification u/s 154 for correct assessment year of DDT. Revenue argued DDT pertained to A.Y. 2014-15, but Section 115-O(3) mandates DDT payment when dividend is declared. DDT must be accounted for in the year it was paid. Assessee rectified Form 3CD for A.Y. 2014-15 and 2015-16 to correct DDT accounting error. CIT(A) rejected revised form, stating it should have been filed before end of relevant assessment year. However, as dividend declaration and DDT payment occurred in A.Y. 2015-16, DDT should be accounted for in A.Y. 2015-16. Assessee's appeal allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4800
Join Channel
TaxTMI 
