Benefit of cost inflation index is available even in respect of foreign assets.
Benefit of cost inflation index is available even in respect of foreign assets. Mumbai Tribunal in the case of Aarav Fragrances and Flavors Pvt. Ltd (ITA 546/Mum/2024) has held that the benefit of cost inflation index for the foreign assets. Let us have a Short Overview of the Case: Aarav Fragrances and Flavors Pvt…. […]
Grant of sanction by the appropriate authority is a precondition for AO to assume valid jurisdiction for issue of 148 notice: Mumbai ITAT
Grant of sanction by the appropriate authority is a precondition for AO to assume valid jurisdiction for issue of 148 notice: Mumbai ITAT Mumbai ITAT post Rajeev Bansal quashes reassessment procedings for AY 2015-16 as well as for AY 2016-17 & 2017-18 Mumbai ITAT in its recent judgement dt 2nd December,2024 in the case… […]
10 year limit applies only prospectively, meaning it does not apply retroactively to assessment years where the old six-year limit has already expired: Delhi HC
10 year limit applies only prospectively, meaning it does not apply retroactively to assessment years where the old six-year limit has already expired: Delhi HC In the case of Sheetal International (P.) Ltd. v. CIT [2024] 168 taxmann.com 308 (Delhi), the Court dealt with a critical issue regarding the issuance of a reassessment notice under Section… […]
NRI Landlords Can Consider This ‘Tax Hack’ to Resolve Money Stuck in TDS Deducted by Tenants
NRI Landlords Can Consider This ‘Tax Hack’ to Resolve Money Stuck in TDS Deducted by Tenants Many NRI landlords face a cash flow challenge when tenants deduct tax at source (TDS) at 30% (plus applicable surcharge and cess) on rental payments. While this is mandatory, the landlord’s actual final tax liability is usually lower… […]
Approval not obtained from PCIT as required under the new provisions – Reassessment notice declared invalid and assessment stood nullified: Mumbai ITAT
Approval not obtained from PCIT as required under the new provisions – Reassessment notice declared invalid and assessment stood nullified: Mumbai ITAT The judgment in the case of ACIT-19(1) v. Manish Financial [ I.T.A. No.5055/Mum/2024; Assessment Years: 2015-16 & 2016-17; Dt. of Judgement: 02.12.2024] [“D” Bench, Mum ITAT] stems from reassessment proceedings involving AYs2015-16 and… […]
Re-assessment notice issued U/s 148 being barred by limitation under the new provisions of section 149(1) is liable to be quashed and set aside.
Re-assessment notice issued U/s 148 being barred by limitation under the new provisions of section 149(1) is liable to be quashed and set aside. The “C” Bench of Mumbai ITAT in ITO v. Pushpak Realities Pvt. Ltd.( ITA No. 4812/Mum/2024; Date of Judgment: 07/11/2024; AY: 2015-16) [Mum ITAT] held that reassessment notice issued under… […]
Delay in filing Form 67 is a procedural lapse that does not affect the substantive right to claim FTC: ITAT
Delay in filing Form 67 is a procedural lapse that does not affect the substantive right to claim FTC: ITAT In a case before 𝗜𝗻𝗰𝗼𝗺𝗲 𝗧𝗮𝘅 𝗧𝗿𝗶𝗯𝘂𝗻𝗮𝗹 𝗼𝗻 𝗙𝗼𝗿𝗲𝗶𝗴𝗻 𝗧𝗮𝘅 𝗖𝗿𝗲𝗱𝗶𝘁, the following issues were involved 1. Denial of Foreign Tax Credit (FTC) due to procedural non-compliance (late filing of Form 67). 2. Whether FTC can be disallowed purely based… […]
GST Advisory: Reporting Differences in Tables 8A & 8C for FY 23-24
GST Advisory: Reporting Differences in Tables 8A & 8C for FY 23-24 The following are the Key Changes: Table 8A: Auto-populated from GSTR-2B for FY 23-24. Table 8C: Manual input for ITC availed in next FY till the cutoff date. Common Scenarios: 1 Late-reported invoices for FY 23-24 → Report in Table 8C &… […]
Delay in filing Form 67 is a procedural lapse that does not affect the substantive right to claim FTC: ITAT
Delay in filing Form 67 is a procedural lapse that does not affect the substantive right to claim FTC: ITAT In a case before Income Tax Tribunal on Foreign Tax Credit, the following issues were involved 1. Denial of Foreign Tax Credit (FTC) due to procedural non-compliance (late filing of Form 67). 2. Whether… […]
𝗜𝗻𝗰𝗼𝗺𝗲 𝗧𝗮𝘅 𝗧𝗿𝗶𝗯𝘂𝗻𝗮𝗹 𝗢𝗿𝗱𝗲𝗿 𝗼𝗻 𝗱𝗶𝘀𝗮𝗹𝗹𝗼𝘄𝗮𝗻𝗰𝗲 𝗼𝗳 𝗙𝗼𝗿𝗲𝗶𝗴𝗻 𝗧𝗮𝘅 𝗖𝗿𝗲𝗱𝗶𝘁
𝗜𝗻𝗰𝗼𝗺𝗲 𝗧𝗮𝘅 𝗧𝗿𝗶𝗯𝘂𝗻𝗮𝗹 𝗢𝗿𝗱𝗲𝗿 𝗼𝗻 𝗱𝗶𝘀𝗮𝗹𝗹𝗼𝘄𝗮𝗻𝗰𝗲 𝗼𝗳 𝗙𝗼𝗿𝗲𝗶𝗴𝗻 𝗧𝗮𝘅 𝗖𝗿𝗲𝗱𝗶𝘁 𝗞𝗲𝘆 𝗜𝘀𝘀𝘂𝗲𝘀: 1. Denial of Foreign Tax Credit (FTC) due to procedural non-compliance (late filing of Form 67). 2. Whether FTC can be disallowed purely based on delay in filing Form 67. 3. Application of Double Taxation Avoidance Agreement (DTAA) between India and Thailand. 𝗙𝗮𝗰𝘁𝘀… […]
