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Showing 1 to 20 of 1821 Records Search Text: tds delivery order charges |
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2017 (1) TMI 266 - ITAT DELHI The Tribunal ruled in favor of the appellant on various issues including disallowance under Section 14A, enhancement of closing inventory value, provision for price increase of raw materials, scrap value addition, provision for advertisement expenses, purchases from related parties, advisory services expenses, commission paid to dealers, disallowance under Section 40(a)(ia) for non-deduction of TDS, treatment of royalty and model fees as capital expenditure, gains from sale of investments, deduction under Section 80IA for power generating unit, and other expenses, allowing most deductions and disallowances made by the assessing officer.
2013 (8) TMI 57 - ITAT DELHI The court upheld the assessee's arguments in various disallowance cases, directing the Assessing Officer (AO) to re-determine disallowances under Section 14A based on a reasonable method, allow payment to LIC for leave encashment under section 37(1), grant additional depreciation for computers in factory areas, and recognize business expenses like repair/maintenance and expansion costs. Disallowances for non-deduction of TDS were re-evaluated, with some disallowances upheld for car rental charges and gifts to game show winners. However, disallowances for various expenses like catering services, room rent, and advertisement expenses were deleted, along with adjustments for transfer pricing and warranty provisions.
2015 (4) TMI 533 - ITAT JAIPUR The ITAT Jaipur Bench addressed issues including unverifiable purchases, rejection of books of account, income estimation, business expenses disallowance, income treatment, "on money" additions, and prior period expenses. ITAT reduced disallowance percentages, confirmed capital gain treatment, deleted "on money" additions, and allowed prior period expenses in various cases.
2017 (9) TMI 1257 - ITAT DELHI The tribunal partly allowed the assessee's appeal and dismissed the revenue's appeal. Various disallowances were deleted, including interest on ECBs, expenses of capital nature, interest on short term loans, and support services expenditure. The tribunal directed verification and re-examination of certain issues related to transfer pricing matters. Penalty proceedings and levy of interest under sections 234B and 234D were dismissed as premature. The tribunal emphasized assessments in compliance with the law and supported by proper evidence.
2015 (3) TMI 490 - ITAT LUCKNOW The Tribunal upheld the CIT(A)'s decision that transportation charges paid to GAIL fall under Section 194C, not Section 194I of the Income Tax Act, 1961. It determined that the charges were part of a composite contract for the sale of gas, not rent, based on the exclusive use of GAIL's capital assets for gas delivery. The Tribunal emphasized the embedded nature of transportation charges in the cost of gas, aligning with prior court decisions and CBDT Circulars. The delay in filing appeals was condoned, and the case was remanded for reassessment of TDS provisions.
2014 (7) TMI 853 - ITAT MUMBAI The Tribunal allowed the exemption under Section 10A for gold medallion exports but denied it for profits from a specific quantity due to lack of evidence. It upheld additions under Section 68 for cash transfers while deleting one for customs duty payments. The addition under Section 68 for amounts received from debtors was deleted. The addition for unaccounted stock sold was deleted. The disallowance of commission payments was remanded for further examination. Losses in diamond trade were allowed. Disallowances under Sections 40(a)(ia) and 40A(2) were disallowed. Deletions of addition for cash transfer, interest expenses, and forward contract losses were upheld.
2023 (1) TMI 65 - ITAT AHMEDABAD The Tribunal upheld that delayed payment charges, interest from customers, income from shifting services, liquidation damages, rebates, sale of scrap, supplier discounts, penalties, late delivery payments, unscheduled interchange income, meter fixing fees, and gains on foreign currency exchange are eligible for deduction under Section 80-IA. Income from the sale of Carbon Credits was deemed a capital receipt not taxable. Disallowance under Section 14A is not warranted without exempt income. Interest expenditure is not disallowed if interest-free funds cover loans. Donations under Sections 80G and 80GGB can be claimed separately. Disallowances under Section 14A cannot be added to book profit under Section 115JB.
2022 (11) TMI 885 - ITAT AHMEDABAD The Tribunal dismissed the assessee's contentions regarding the validity of the CIT(A)'s order and the assessment order being barred by limitation. The Tribunal allowed the treatment of speculative loss as business expenditure, disallowed transaction charges due to lack of TDS deduction evidence, directed full depreciation allowance, upheld genuine business expenses related to debit notes, deleted disallowance of interest on advances, confirmed disallowance of employees' contributions delay, and deleted unexplained cash credit addition, emphasizing business purpose and proper accounting.
2024 (2) TMI 1238 - ITAT RAJKOT The Tribunal dismissed all appeals from both the Assessee and the Department. It upheld the CIT(A)'s determinations that "Time Charter Hire Charges" qualify as Royalty under Section 9(1)(vi) of the IT Act, that no specific time limit applies for orders under Section 201(1) and 201(1A), that the non-resident company lacks a business connection or PE in India, and rejected the bona fide belief defense for non-deduction of taxes at source.
2019 (4) TMI 1509 - ITAT DELHI The Tribunal ruled in favor of the assessee on various issues including transfer pricing adjustments, freight inward/import clearing expenses, provision for increase in material price, prior period expenses, advertisement provisions, excessive purchases from related parties, payments for advisory services, TDS on discounts, disallowance of legal expenses, royalty expenditures, gains from investments, and CSR expenses. The Tribunal allowed most of the assessee's claims, finding them to be in compliance with relevant laws and agreements. Disallowances were overturned due to lack of adverse material or incorrect application of tax provisions.
2021 (9) TMI 1400 - ITAT DELHI The Tribunal held that the credits received from International Aero Engines (IAE) were capital receipts not subject to tax. It disallowed the proportionate lease rental payments under section 37(1) as they were not linked to the credits received. Additionally, the Tribunal allowed the supplementary lease rent payments, stating that TDS provisions did not apply. The appeals by both the assessee and the Revenue were resolved in accordance with these findings.
2017 (7) TMI 1076 - RAJASTHAN HIGH COURT The case involved issues regarding tax withholding under Section 194H of the Income Tax Act, reliance on internal records over statutory books, interest levies under Sections 201(1A) and 220(2), penalty imposition under Section 271C, liability under Section 201, and TDS applicability under Section 194J. The Tribunal erred in its interpretations, leading to a ruling in favor of the assessee. It was held that no tax withholding was required, interest and penalty were unjustified, and TDS on roaming charges was deemed inapplicable. The appeals by the assessee were allowed, while those by the department were dismissed.
2019 (2) TMI 1198 - ITAT MUMBAI The Tribunal directed the AO to verify evidence and re-compute various additions made, including oversold positions, interest on securities, trading profits, and transactions with specific parties. The CIT(A)'s directions were upheld, and the Tribunal dismissed certain grounds related to deductions and allowances. The AO was directed to re-compute interest levied under specific sections and treat speculative loss as a normal business loss. The Tribunal also upheld the rejection of the cash system of accounting and allowed set-off of additions against unexplained investments or expenditures.
2020 (10) TMI 605 - ITAT BANGALORE The tribunal ruled in favor of the taxpayer on various issues including setting off losses of STPI/SEZ units against non-STPI/non-SEZ unit income, inclusion of miscellaneous income for deductions under sections 10A/10AA/10B, eligibility of deemed exports for deductions, and foreign tax credit allowance. The tribunal directed the AO to reexamine certain issues in line with decisions from the Karnataka High Court and other judicial precedents. Issues such as exclusion of certain incomes for deductions, transfer pricing adjustments, and disallowances were also addressed with specific instructions for further review or allowance.
2017 (4) TMI 1092 - ITAT MUMBAI The Tribunal partly allowed the assessee's appeal, granting relief on transfer pricing adjustment, disallowance under section 14A, and alleged bogus purchases. The Tribunal directed the AO to verify and grant appropriate credits and adjustments, dismissing other grounds such as penalty proceedings and interest charges under sections 234B and 234C.
2012 (11) TMI 1301 - ITAT BANGALORE The Tribunal partly allowed the appeals for A.Y 2006-07 and 2007-08, remanding several issues back to the AO for fresh consideration. Disallowance of expenses related to South Elegant Limited (SEL) was upheld due to lack of original agreements and non-existence of SEL. Various claims under different heads were either disallowed or restricted, with the Tribunal emphasizing the need for verification of details. Remuneration paid to the Managing Director was allowed, while rent received from a sister concern and the applicability of Section 201 were remanded back for further verification.
2019 (3) TMI 1612 - ITAT PUNE The Tribunal partly allowed the assessee's appeal and dismissed the Revenue's appeal. It directed the Assessing Officer to reconsider certain disallowances while upholding the CIT(A)'s decisions on other issues, ensuring a thorough examination of the facts and legal provisions involved.
2018 (10) TMI 66 - ITAT CHENNAI The case involved various issues including suppression of sales, addition for cash credits, disallowance of exchange rate fluctuation loss, and disallowance for personal use of cars. The Commissioner of Income-tax (Appeals) ruled in favor of the assessee on some issues, deleting additions for suppression of sales and low drawings but upholding others like disallowance for personal use of cars. The Tribunal also made decisions, deleting additions for insufficient drawings and credit balance in sundry debtors account. Ultimately, the case resulted in a mixed outcome with some additions being upheld and others being deleted based on the evidence and explanations presented.
2018 (7) TMI 208 - ITAT DELHI The Tribunal ruled in favor of the assessee on various issues including transfer pricing adjustment, freight inward/import clearing expenses, cost of rejection of goods, provision for price increase, scrap material cost, prior period expenses, advertisement provisions, excessive purchases from related parties, deemed dividend, payments for advisory services, TDS deductions, legal and professional expenses, royalty expenditure, depreciation, foreign travel expenses, advertisement expenses, commissions, CSR expenses, outsourcing deduction, profit attribution, incidental income, compliance with rules, repair and maintenance expenses, and mobile phone expenses. The disallowances were deleted, and adjustments in favor of the assessee were made accordingly.
2007 (1) TMI 198 - ITAT BOMBAY-E The tribunal determined that the Assessing Officer's action was barred by limitation for payments made before 31-3-1998. Payments made after obtaining an NOC under section 195(2) were not in default. The issue concerning Core Laboratories was remanded for re-adjudication. The tribunal upheld the CIT(A)'s order with specified modifications. Interest under section 201(1A) was deemed consequential, requiring appropriate relief. Both revenue appeals were dismissed due to lack of COD approval, while the assessee's appeals were partly allowed.
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