when indian co buys services from AE abroad there are no other transactions to compare AE has not sold services to 3rd party except indian counterpart which method will justify ALP ?
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To ADMN. Regret that my query posted on the Topic, a few days ago, has thus far remained to elicit an eminent ANSWER from your inhouse EXPERT; will you please have it attended ! To Add: As per my information, in US and HK, - may be , in certain other countries as well, - unlike in India, there is no taxation of 'perquisite' - hence no TDS, by employer-company in the year in which RSU is vested. That is, unlike in India , RSU attracts tax liability (CGT) only on its 'Sale ', in the year of sale .
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Regarding the deduction available u/s 24b of Income Tax Act, Can a son who is the co-borrower of the loan taken for construction of house claim the deduction u/s 24(b). Please note that he is not the owner/co-owner but complete EMI is getting deducted from his bank savings account. His mother is the only owner of the property. Sec 24(b) applicable where the property has been acquired, constructed, repaired, renewed or reconstructed with borrowed capital, the amount of any interest payable on such capital: Please help on this issue. Thanks
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Notice under section 148 was issued on 22 March 2017 which mentioned that return of income needs to filed within 30 days. However ROI pursuant to notice under section 148 was filed on 15 December 2017 i.e., after the due date mentioned in 148 notice. Order was passed under section 143(3) read with section 147 of the Act. Is it still mandatory to issue notice under section 143(2) even if the ROI was filed beyond the time limit provided in notice under section 148?
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M/S. ABC is partnership firm, having 4 partners. As per retirement deed executed on 31.03.22, two partners retire from the firm w.e.f.1.04.2022. As on the date of retirement these two partners were debit balalce in the firm. Firm is continued by the continuing partners and writoff the amount due from the retirng partner and claimed as expenditure. 1. Whether firm can claimed this As expenditure? 2. Whether any tax liability in the hands of firm ? 3. Tax implication in the hands of partner ? Whether they are liable to pay tax on amount payable by them to firm?
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Assessee is trust registered Bombay Public trust Act and running a school and is not receiving any grant from GOVt. Filed the Return of income for AY. 2018-19. INTIMATION u/Sec. 143(1) is received where entire Gross receipts were considered as taxable at MMR and later on case was selected for scrutiny , where AO assessed the income as determined by the CPC U/Sec. 143(1)(a). Assessee filed an appeal against the assessment order passed U/Sec. 143(3) . NOW PCIT has issued NOtice U/sec. 263 on the ground that no question was asked to assessee about it's claim U/Sec. 10(23) and no…
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The Trust derives income of 2Lakh from immovable property rent only and part of the funds are donated to national causes. No exemption from I.T Comm. had been taken as of yet. Members has no share of undetermined or determined funds. In fact the working is voluntary. Why CPC applied sec 167 and demand surcharge of 37% total of 42%. Grievance was file to CPC stating no funds share either determined or undetermined was with the members. AY 2021-22 & 2022-23 CPC levied surcharge levied at 37% What to do as to give CPC reply and how the surcharge is…
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An assessee purchased a builiding in 2002 an made certain improvements thereafter . The building was old and was demolished in 2021. The assessee is now selling the land. What shall be cost of acquisition for tax purpose the cost of building and improvement the value of land only
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The issue relates to A. Y. 2021-22 which was Covid-2019 pandemic period. The education institution incurred loss of Rs.2.89 Cr. for the reason that the fees from student reduced substantially while the expenditure on salary allowances continued as usual. The accumulation u/s.11(2) for A.Y. 2015-16 and 2016-17 was utilised to set off the loss arising due to peculiar circumstances. The deemed income u/s. 11(3) to the extent of Rs.2.89 Cr. was considered in the computation of income. The net result of computation was Nil. My question is whether the loss can be adjusted from the deemed income u/s. 11(3).
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If the assessee has filed an appeal before CIT. But now assessee has to file application for revision of order under section 264. Can assessee can do so? As withdrawal of appeal is not allowed and as per section 264(4) assessee cannot file application for revision of order if his appeal is pending before CIT(A)
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Transfer pricing