Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
The case involves rectification u/s 154 for disallowance of bad debts provisions u/s 36(1)(viia) in a co-operative bank's computation sheet. ITAT held that the mistake was apparent as the provision was not in the books. CIT(A) noted rectification requires a glaring mistake of law. ITAT found the claim ineligible and rectified u/s 154. CIT(A) noted a similar deduction in a subsequent year but the provision was duly accounted for. AR argued for deduction based on Companies Act provisions, but ITAT found no support for allowing the claim if not in books. Following precedent, ITAT remitted the matter to AO to allow deduction based on actual provision made in books. Revenue's appeal partly allowed for statistical purposes.
The case involves rectification u/s 154 for disallowance of bad debts provisions u/s 36(1)(viia) in a co-operative bank's computation sheet. ITAT held that the mistake was apparent as the provision was not in the books. CIT(A) noted rectification requires a glaring mistake of law. ITAT found the claim ineligible and rectified u/s 154. CIT(A) noted a similar deduction in a subsequent year but the provision was duly accounted for. AR argued for deduction based on Companies Act provisions, but ITAT found no support for allowing the claim if not in books. Following precedent, ITAT remitted the matter to AO to allow deduction based on actual provision made in books. Revenue's appeal partly allowed for statistical purposes.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
