Receipt of immovable property requires actual possession or enjoyment; redevelopment allotments exchanged for tenancy rights fall outside deemed incom...
Section 80P deduction covers Souharda credit societies, including qualifying surplus-deposit interest, subject to member KYC verification for cash dep...
Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallo...
The case involved reimbursement of expenses u/s 195 of the Income Tax Act, concerning payments made for services rendered outside India. The payments to various entities were found to fall under exclusionary provisions of Section 9(1)(vii)(b), as they were for earning income from a source outside India. Disallowance u/s 40(a)(i) was deemed unwarranted and ordered to be deleted. Transactions with Carnegie Mellon University, Call Centre School LLC, APM Group, British Computer Society, RADTAC, and an individual for professional services were similarly analyzed and disallowances were overturned, citing legal provisions and tax residency status. The ITAT allowed the appeals of the assessee in all instances.
The case involved reimbursement of expenses u/s 195 of the Income Tax Act, concerning payments made for services rendered outside India. The payments to various entities were found to fall under exclusionary provisions of Section 9(1)(vii)(b), as they were for earning income from a source outside India. Disallowance u/s 40(a)(i) was deemed unwarranted and ordered to be deleted. Transactions with Carnegie Mellon University, Call Centre School LLC, APM Group, British Computer Society, RADTAC, and an individual for professional services were similarly analyzed and disallowances were overturned, citing legal provisions and tax residency status. The ITAT allowed the appeals of the assessee in all instances.
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