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Search Results for "ITAT order"

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High Court

Bombay High Court Dismisses Assessee's Appeal in Income Tax Case for Non-Compliance with Section 144B and Upholds 12.5% Disallowance of Expenditure. The court held that the assessment order was not vitiated by non-compliance with Section 144B as the assessee was given adequate opportunity, and the disallowance of 12.5% of expenditure was justified due to lack of proper verification.

19 Jun 2026

The case involves an appeal filed by Accost Media LLP (the assessee) under Section 260A of the Income Tax Act, 1961, challenging the order of the Inco...

High Court

Bombay High Court Dismisses Assessee's Appeal in Income Tax Revision Case for Lack of Inquiry by Assessing Officer. Revision under Section 263 of Income Tax Act, 1961, sustained as Assessing Officer failed to examine revenue reconciliation and reimbursement of expenses, making assessment order erroneous and prejudicial to Revenue.

19 Jun 2026

The appellant-assessee, Mirum Digital Pvt. Ltd., is engaged in digital marketing and buys media space from online platforms like LinkedIn, Google, etc...

High Court

Bombay High Court Dismisses Revenue's Appeal in TDS Classification Dispute — Holds Payments to Full-Time Consultant Doctors Fall Under Section 194J, Not Section 192, and Annual Maintenance Contract Payments Are Under Section 194C, Not Section 194J. The court affirmed that the absence of employer-employee relationship and the nature of maintenance contracts do not attract TDS under sections 192 or 194J.

15 Sep 2025

The Bombay High Court dismissed six appeals filed by the Revenue (Commissioner of Income Tax, TDS-1, Mumbai) against the order of the Income Tax Appel...

High Court

Bombay High Court Allows Assessee's Appeal in Bogus Purchases Case — Disallowance of 10% Purchases Set Aside. ITAT's finding that AO's order was not based on cogent evidence required full deletion of addition, not partial disallowance.

15 Oct 2024

The case involves three Income Tax Appeals filed by the Assessee, Ashok Kumar Rungta, challenging the ITAT's order dated August 9, 2017, which upheld ...

High Court

Bombay High Court Allows Revenue Appeal in SAP System Royalty Case — Payments for Use of Computer Software Constitute Royalty Under Section 9(1)(vi) of Income Tax Act, 1961. The court held that payments for use of SAP system and related services are taxable as royalty and fees for technical services, reversing the ITAT order.

21 Jun 2023

The present appeal was filed by the Revenue (Commissioner of Income Tax) challenging an order dated 25th January 2017 passed by the Income Tax Appella...

High Court

Bombay High Court Allows Revenue's Appeal in Income Tax Case Involving Non-Resident Company - Denial of Treaty Benefits and Business Connection Upheld. The court held that the Tax Residency Certificate is not conclusive and the Assessing Officer can examine the substance of the arrangement to determine treaty eligibility.

16 Jun 2023

The case involves an appeal by the Commissioner of Income Tax (International Taxation) against the order of the Income Tax Appellate Tribunal (ITAT) i...

Supreme Court

Supreme Court Allows Revenue Appeal in Income Tax Case — Rectification Deed Held Invalid for Reducing Consideration Without Commercial Substance. The Court restored the addition of Rs. 10,69,79,146/- made by the Assessing Officer under the Income Tax Act, 1961, holding that the rectification deed was a colourable device to evade tax.

22 Mar 2022

The case involves an appeal by the Revenue against the judgment of the Bombay High Court which dismissed its appeal and confirmed the order of the Inc...

Supreme Court

Supreme Court Quashes ITAT Order Recalling Its Earlier Order Under Section 254(2) of Income Tax Act — Powers Limited to Rectification of Mistake Apparent from Record. The ITAT cannot re-hear the entire appeal on merits under the guise of rectification; the remedy against an erroneous order lies in appeal before the High Court.

3 Dec 2021

The case involves appeals by the Revenue against a common judgment of the Bombay High Court, which dismissed writ petitions challenging an order of th...

High Court

Bombay High Court Allows Writ Petition Challenging Form-3 Under Direct Tax Vivad Se Vishwas Act, 2020 for Assessment Year 2003-2004 — Designated Authority Directed to Recompute Amount Payable After Considering Refund Already Paid. The Court held that the Designated Authority must consider refunds paid under Section 244A of the Income Tax Act, 1961 while computing the amount payable under the DTVSV Act, and apply the principle of set off under Section 245 of the IT Act.

25 Aug 2021

The Petitioner, Cooperative Rabobank U.A., a bank established in the Netherlands and part of the Rabobank Group, is a regular assessee under the Incom...

Supreme Court

Supreme Court Upholds High Court in Capital Gains Tax Case — Accrual Occurs on Date of Award, Not Notification. Transfer of Capital Asset Under Section 45 of Income-tax Act, 1961 Is Complete Only When Compensation Is Determined by Collector's Award, Even if Possession Taken Earlier.

25 Aug 2020

The case concerns the assessment year 1971-1972 for the assessee Amrik Singh HUF, whose land was acquired by the Haryana Government for a college play...

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