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Can a manufacturer claim Input Tax Credit (ITC) on transmission-line assets installed outside the factory premises

Facts of the case:  The applicant, Alleima India Pvt. Ltd., operating a manufacturing plant in Gujarat, expanded production capacity and required enhanced power supply.  To meet the requirement, the company laid an underground cable line from a substation of Gujarat Energy Transmission...

Can Netflix India be treated like Netflix’s global brain?

In the last few years, India’s tax authorities have increasingly questioned how digital businesses operate within the country. But few cases captured the industry’s attention like the one involving Netflix India. What started as...

CAs Gain Equal Recognition for ITAT Appointments

The Institute of Chartered Accountants of India (ICAI) recently celebrated a landmark judgment by the Supreme Court of India that marks a significant win for Chartered Accountants in the legal and tax professions. On...

Does Section 115BAA Override Special Tax Rates?

The central issue before the Delhi Bench of the Income Tax Appellate Tribunal (ITAT) in Maharishi Education Corporation (P.) Ltd. vs. ITO  was:  Whether a company opting for the concessional tax regime under Section 115BAA is required to pay tax...

Can a PCIT introduce new issues in a Section 263 order without mentioning them in the Show Cause Notice? 

1. Issue  The central issue before the Income Tax Appellate Tribunal (ITAT), Delhi Bench ‘B’, was whether the Principal Commissioner of Income Tax (PCIT) validly exercised revisionary jurisdiction under Section 263 of the Income-tax Act, 1961, when:  The PCIT travelled beyond the scope of the...

Can “Diary Notings” and “Retracted Statements” Alone Sustain an Addition? 

In appellate tax practice, the truth is simple: a case is only as strong as the evidence that supports it.  In a recent landmark decision, the Income Tax Appellate Tribunal (ITAT), Mumbai Bench, delivered a judgment that...

Can Profit Be Taxed Twice on the Same Bogus Purchase? 

When books of accounts are accepted, can the Assessing Officer still tax “profit” on alleged bogus purchases again?  In a recent decision, the ITAT Delhi Bench ‘C’ delivered an insightful order in the case of...

Whether the delay of 304 days in filing the appeal deserved to be condoned in absence of any explanation or affidavit ? 

In the complex world of appellate tax litigation, time isn’t just a procedural formality it’s often the deciding factor between justice and finality.  The Income Tax Appellate Tribunal (ITAT), Ahmedabad Bench, recently delivered a detailed...

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