Category: Income-Tax Act

Archive for the ‘Income-Tax Act’ Category


Johnson Matthey Chemicals India P. Ltd. v. Dy. CIT (2021) 90 ITR 75 (SN) (Pune)(Trib.)

S. 92C : Transfer pricing-Arm’s length price-Consultancy services-Matter remanded.

Invitrogen Bioservices India Pvt. Ltd. v. ACIT (2021) 90 ITR 91 (SN) (Bang.)(Trib.)

S. 92C : Transfer pricing-Arm’s length price-Functional dissimilarity-Product company having inventories and undertaking very high level research work-Excluded from list of comparable Companies. [S. 92CA]

Dell International Services India P. Ltd. v. Add. CIT (LTU) (2021) 90 ITR 61 (SN.) (Bang.)(Trib.)

S. 92C : Transfer pricing-Arm’s length price-Functionally different-Cannot be comparable.

Venoor Co-Operative Agricultural Bank Ltd. v. ITO (2021) 90 ITR 20 (SN) (Bang.)(Trib.)

S. 80P : Co-operative societies-Interest and dividend-Profits attributable to activity of providing credit facilities to its members-Matter remanded to the Assessing Officer. [S. 80P(2)(a)(i), 80P(2)(d)]

Potters Cottage Industrial Co-Operative Society Ltd. v. ITO (2021) 90 ITR 73 (SN) (Bang.)(Trib.)

S. 80P : Co-operative societies-Members to be construed as per definition of Concerned Co-Operative Societies Act-Matter remanded-Interest from investment in Co-Operative Societies eligible for deduction-Interest from any Bank which is not-Co-Operative Society is not eligible for deduction. [S. 80P(2))(a), 80P(2)(d)]

ITO v. Maharashtra State Co-Operative Credit Societies Deposit Guarantee Corp. Ltd. (2021) 90 ITR 36 (SN) (Pune)(Trib.)

S. 80P : Co-operative societies-Income from sale of mutual funds to be taxed as capital gains-Interest on fixed deposits taxable as income from other sources”-Loss for year and brought forward loss from sale of mutual funds to be set off. [S. 45, 70, 71, 80P(2)(a)(i)]

ITO v. Maharashtra State Co-Operative Credit Societies Deposit Guarantee Corp. Ltd. (2021) 90 ITR 36 (SN) (Pune)(Trib.)

S. 80P : Co-operative societies-Income from sale of mutual funds to be taxed as capital gains-Interest on fixed deposits taxable as income from other sources”-Loss for year and brought forward loss from sale of mutual funds to be set off. [S. 45, 70, 71, 80P(2)(a)(i)]

Hyde Park (A) Co-Operative Housing Society Ltd. v. ITO (2021)90 ITR 50 (SN) (Pune)(Trib.)

S. 80P : Co-operative societies-Set-off of expenditure-Interest Income-Matter remanded for verification to ascertain ehther the expenditure was incurred exclusively for maintenance of housing Society. [S. 56, 57, 80P(2)(d)]

OnMobile Global Ltd. v. Add. CIT (2021) 90 ITR 18 (SN) (Bang.) (Trib.)

S. 80JJAA : Employment of new workmen-Certificate in form 10DA-High salaries cannot be the basis for denial of exemption.

Rasna Pvt. Ltd. v. Dy.CIT (2021) 90 ITR 39 (SN) (Ahd.)(Trib.)

S. 80IC : Special category States-Failure to allocate financial expenses-Assessee allocating on the basis of ratio 58. 67 %-The Assessing Officer computing 58.69%-Held to be justified.