Category: Income-Tax Act

Archive for the ‘Income-Tax Act’ Category


Intas Pharmaceuticals Ltd. v. ACIT (2024)114 ITR 434 (Ahd)(Trib)

S. 40A(2): Expenses or payments not deductible-Excessive or unreasonable-Payment to related parties-Deletion is justified. [S.40A(2)(b)]

Hindalco Industries Ltd. v. Dy. CIT (2024)114 ITR 502 (Mum)(Trib)

S. 40A(2): Expenses or payments not deductible-Excessive or unreasonable-Service charges paid to group company-Common management services-Disallowance is deleted.

Punj Lloyd Alcon Lk Goyal (JV) v. ITO (2024)114 ITR 36 (SN)(Delhi)(Trib)

S. 40(a)(ia): Amounts not deductible-Deduction at source-Mobilisation advance-Joint venture-Issue restored to Assessing Officer for verification.

ACIT v. First Advantage P. Ltd. (2024)114 ITR 45 (SN)(Mum)(Trib)

S. 40(a)(ia): Amounts not deductible-Deduction at source-Payments to contractors and professional or technical service fee-Deducted lower rate of tax-Disallowance is not justified.[S.194C, 194J]

Intas Pharmaceuticals Ltd. v. ACIT (2024) 114 ITR 546 (Ahd) (Trib)

S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident-Commission-Disallowance is deleted.

Intas Pharmaceuticals Ltd. v. ACIT (2024)114 ITR 434 (Ahd)(Trib)

S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident-Commission expense-Additional ground not considered-Matter remanded for de novo consideration. [S. 254(1)]

Malbros Holdings P. Ltd. v. ITO (2024) 114 ITR 25 (SN)(Delhi)(Trib)

S. 37(1) : Business expenditure-Amortisation of expenditure-Roc fees for share application money amortised over five years-Allowable as deduction.

Global Tech India P. Ltd. v. ITO (2024)114 ITR 59 (SN)(Ahd)(Trib)

S. 37(1) : Business expenditure-Capital or revenue-Product development expenses-Project dropped and expenses written off-No new software in existence and no enduring benefit-Allowable as revenue expenditure.

ACIT v. Ludhiana Beverages P. Ltd. (2024) 114 ITR 81 (SN)(Amritsar)(Trib)

S. 37(1) : Business expenditure-Entertainment expenses-Major expenses are through banking channel-Rebates and discounts-Revenue cannot decide what constitutes reasonable expenditure-Enterprise resource planning software expense-Capitalised in books of account-Allowable as revenue expenditure, though the claim was not made in the original or revised return-Advertisement expenses-Purchase of Ice boxes, plastic tables and chairs, bearing logo-Allowable as business expenditure. [R. 46A]

ACIT v. Jindal Poly Films Ltd. (2024)114 ITR 72 (SN)(Delhi)(Trib)

S. 37(1) : Business expenditure-Payments to contractors for packing, loading and unloading-Opportunity of cross examination is not given-Disallowance is deleted.[S. 153A]