* IN THE HIGH COURT OF DELHI AT NEW DELHI
Reserved on: 17.11.2016
Pronounced on: 03.07.2017
+ ITA 240/2004
COMMISSIONER OF INCOME TAX ..... Appellant
Through : Sh. Raghvendra Singh, Sr. Standing
Counsel and Sh. Rahul Chaudhary, Advocate.
versus
M/S. MODILUFT LTD. ..... Respondent
Through : Sh. Amar Dave and Sh. Abhinav
Sharma, Advocates.
CORAM:
HON'BLE MR. JUSTICE S. RAVINDRA BHAT
HON'BLE MR. JUSTICE SANJEEV SACHDEVA
MR. JUSTICE S. RAVINDRA BHAT
%
1. The question of law framed in this appeal under Section 260A of the
Income Tax Act, 1961 [hereafter "the Act"] is as follows:
"Whether the Income Tax Appellate Tribunal was correct in
law in setting aside the order passed under Section 201(1) and
201(1A) of the Income Tax Act, 1961."
2. The assessee used to operate scheduled airlines; it closed down that
business in 1996 due to which its staff, including pilots were laid-off. For
AY 1997-98, the assessee filed its return on 29.11.1997. The Assessing
Officer (AO) picked up the case for scrutiny and completed assessment
under Section 143(3) of the Act. The assessee filed Tax Deducted at Source
(hereafter "TDS") returns under Section 206 of the Act in Form 24 on
ITA 240/2004 Page 1 of 11
26.03.1998, declaring the TDS, and deposited ` 1,06,89,369/-. The AO
observed that Capt. J.H. Patel who was an Executive Pilot for four months in
1996 (for the period April-August 1996) had complained, that he was paid a
net salary of ` 7,72,500/- after TDS of ` 5,32,380/- and Provident Fund of `
32,250/- but that no Form-16 was issued. The AO stated that similar
information was received from the Ludhiana Special Range office of the
Income Tax authorities in relation to Capt. A.K. Vohra that though his gross
salary was ` 15,28,058/- of which TDS was ` 6,15,980/-, yet Form-16
issued by the company reflected gross income of ` 7,71,600/- and TDS of `
2,75,640/-. The AO also observed that a complaint was received from the
Economic Intelligence Bureau of the Department of Revenue, stating that
larger sums were deducted towards TDS but the entire amounts were not
paid to the authorities. To verify the genuineness of the complaints and the
information, the AO scrutinized the assessee's Form 24 and asked it to
furnish relevant information. After seeking several dates towards
accommodation, the assessee, by letter dated 05.06.2000 stated that its
relevant records were destroyed in fire and that it was unable to supply the
information. The AO asked a specific query with respect to the variation in
TDS amounts shown in the salary slips issued by the assessee to three
individuals, i.e. Capt. A.K. Vohra, Capt. S.C. Mehta and Capt. J.H. Patel and
the actual TDS amounts deposited in respect of such individuals.
3. By its reply dated 21.08.2000, the assessee informed the revenue that
salary was a subject matter within the domain of M/s. Lufthansa, and its
Senior Vice President (Operations). It was also stated that salaries depended
on the individual contracts entered into between the employer and the officer
ITA 240/2004 Page 2 of 11
concerned. The assessee's position was that individual contracts were made
available to the revenue and that since they were authentic documents
binding on both parties, they were adhered to by the company. It was further
stated that the salaries were worked out on the basis of agreements and that
taxes were paid accordingly. It was further stated that the TDS certificate in
Form 16 in the case of Capt. A.K. Vohra was received by him and even
contained his signatures. This signified that he had no objection with regard
to the contents, i.e. amounts deducted and deposited. In the absence of any
complaint or letter from Capt. A.K. Vohra, claiming that TDS certificate for
amounts more than what was paid to him were issued, the revenue's stand
could not be accepted. It was further stated that the company had ceased its
operation in the middle of 1996 after which it did not have any records.
4. The AO observed on the basis of information furnished by the three
Executive Pilots and further information through pay slip furnished by Capt.
B.S. Sandhu that larger or higher amounts were deducted from the salaries
given to such employees but a lesser amount was deposited. On the basis of
analysis of the materials furnished by such pilots, the AO concluded that
there was a liability of tax to the tune of ` 67,90,382/- in respect of 31 pilots.
In addition to that amount determined as the assessee's liability, the AO
calculated interest under Section 201(IA) of the Act to the extent of `
60,66,265/-. The aggregate of this demand formed the basis of the
assessment. The assessee unsuccessfully appealed to the CIT.
5. The assessee's appeal to the ITAT was, however successful. The
ITAT concluded that the adverse findings with respect to collection of higher
amounts but deposit of much smaller amounts was not based upon any
ITA 240/2004 Page 3 of 11
credible findings. It, therefore, set aside the findings of the AO and also the
CIT. The ITAT reasoned inter alia as follows:
"16. As per Section 206 of the Act, the assessee has to file the
return of TDS in Form No.24 indicating the tax deducted at
source and deposited to the government. The assessee company
filed such return on 26.3.1998 indicating the TDS of
Rs.1,06,89,369/- and deposited the same to the government.
Such TDS included the TDS of Rs.57,65,092/- deducted from
the remuneration paid to 31 pilots. On the basis of complaint by
three pilots, the AO concluded that actually the assessee
company has deducted tax at source at Rs.1,20,47,313/- from
the remuneration paid to 31 pilots. In other words, it was not
the case of the revenue that the assessee company has short
deducted tax at source. The case of the revenue is that actually
the assessee has deducted tax at source at Rs.1,20,47,313/-
from the remuneration paid to 31 pilots but it has paid to the
government only Rs.57,65,092/-. This observation of the AO
has to be therefore, examined. As mentioned earlier, the
assessee company filed the return of TDS in Form No.24 giving
information of remuneration paid to 31 pilots and the tax
deducted at source as well as paid to the Govt. as per law. The
AO had observed that the complaints were received from three
pilots to the effect that they were paid higher remuneration and
higher tax was deducted at source. In one case, the pilot also
furnished copy of pay slips allegedly issued by the assessee
company indicating higher remuneration and higher deducted
at source. The AO wanted to verify the contents of such
complaints. He issued summons to some pilots. In response to
such summons, some pilots appeared/confirmed the
remuneration paid to them and tax deducted at source which
confirmed to the claim of the assessee company. In none of the
cases any pilot converted the stand of the assessee company.
The AO has also referred to the information received from one
pilot Shri B.S. Sandhu. The contents of the complaint have been
mentioned by the AO on page 5 of his order. The reading of the
complaint nowhere whispers that higher tax was deducted at
source and he was issued TDS certificate of lesser amount.
ITA 240/2004 Page 4 of 11
Actually, the complaint was to the effect that he has not been
paid his outstanding dues and he has not been issued TDS
certificate due to which he would not file his income tax return.
However, this complaint has nothing to do with the provisions
of Section 201(1)/201(A) of the Act. If the outstanding dues
have not been paid to him, the revenue cannot help it. If the
TDS certificate was not issued to him, there was violation and
different section of the Act deals with such situation. But
certainly this cannot be a case of any occasion under Section
201 of the Act. Thus, reliance on such information was
misplaced.
17. Admittedly, the assessee had employed 31 pilots. Three
pilots complained against the assessee. Some pilots
corroborated the statement of the Assessee company directly
before the AO. Still the AO held that the assessee has deducted
higher taxes from the remuneration paid to all 31 pilots and
failed to make payment of the same to the government. We fail
to understand the logic of the lower authorities in this regard.
Perhaps the revenue's observations would have got some force
if the AO had held that the assessee company has collected
higher TDS from the remuneration paid to three pilots but
failed to pay the same to the government. But that is not the
case of the revenue.
18. The AO has held the assessee in default of the provisions
of Section 201(1) of the Act. This section is applicable where
the assessee has defaulted the tax at source (in the case before
us) but failed to pay the same to the government as per law. But
in order to attract the provisions of Section 201(1) of the Act,
the revenue has to prove conclusively that the tax has been
deducted at source which the assessee company failed to pay to
the government. Except the assertion of the lower authorities on
the basis of complaint received from three pilots, there is
nothing on record to suggest that higher tax has been deducted
as source from the remuneration paid to 31 pilots which the
assessee failed to pay to the government. While holding the
assessee company in default of payment of TDS to government,
the AO did not think it proper to verify that the pilots including
ITA 240/2004 Page 5 of 11
these three pilots from whom the complaint was received have
filed their returns of income and what salary has been declared
by them in their returns. These pilots filed their returns of
income, they should have enclosed the TDS certificate issued by
the assessee company. Whether such certificates depicted any
higher remuneration and higher deduction of tax at source or
not, we had made a specific query in this regard as to whether
in any of the case of 31 pilots, the higher tax was deducted at
source than what was mentioned in the TDS certificate issued
by the assessee company. The revenue had admitted that no
such information was available with them. As against this fact,
we find that when the TDS certificate in Form No.16 was issued
to the pilots including the pilots from whom the complaints
have been received, the same was received by them and their
signatures were also obtained as a token of having received
their TDS certificates. In one of the cases any pilots informed
the assessee company that higher tax was deducted from their
remuneration and the TDS certificate of lower was issued to
them. We also find that the AO has mentioned about certain pay
slips and TDS certificate allegedly issued by the assessee
company to some pilots. But once the assessee company has
flatly denied the issuance of such pay slips, there was no
evidence with the revenue to result such submissions. Thus,
reliance on such alleged pay slips also cannot be placed. On
the basis of above facts, it is clear that the revenue has failed to
evidence its claim that the assessee was in default of not paying
the tax deducted at source as per law......."
6. The revenue argues in its appeal as well as before this Court that the
ITAT misappreciated the facts and evidence. The versions of the pilots,
particularly Capt. Sandhu and Capt. A.K. Vohra were damaging for the
assessee and it was incumbent upon it to explain with full details what were
the amounts actually paid to its employees and pilots and what amounts were
deducted. Its failure to provide any primary material in this regard showed
that it did not discharge the onus of proving that the entire amounts deducted
ITA 240/2004 Page 6 of 11
from the employees' salaries were in fact deposited. Once this pattern of
behavior was corroborated in respect of at least three pilots, the Revenue and
the AO acted within their rights in concluding that all pilots numbering 31
had also received the same treatment. Therefore, the AO correctly deduced
that an amount in excess of ` 67 lakhs was unlawfully retained. In the
circumstances, interest was also leviable. It was also submitted that the
assessee's contention with respect to absence of records was a pretext and
afterthought which was unverifiable and not substantiated in any objective
manner. On the other hand, there was credible material for the AO to infer
that a variation of 208% between the tax shown in Form 24 and the amount
actually deducted by the company existed.
7. Learned counsel for the assessee submits that the ITAT's reasoning is
justified. As a matter of fact, the ITAT drew the correct conclusion from the
complaint of Capt. Sandhu by holding that his grouse was in respect of non-
payment of salary rather than withholding amounts that were not paid by the
assessee to the income tax department. Furthermore, the assessee had never
admitted that the pay slips relied upon by those individuals who complained
to the Revenue were genuine. It was argued on behalf of the assessee that the
consistent stand in all proceedings was that there was no discrepancy
between the written agreements entered into by the parties and the amounts
paid actually. If the written agreements of all the concerned pilots were
verified and tallied with Form 24 furnished, there would have been no
difficulty. Equally, it was pointed out that none of the complainants or the
other pilots answered the summons issued under Section 131 of the Act,
much less supported the allegations against the assessee. Again, no attempt
ITA 240/2004 Page 7 of 11
was made by the Revenue to get hold of the records relating to the returns
filed by the appellants and cross-check them with the TDS returns filed,
especially, by comparing Form 24. In these circumstances, the findings of
the CIT were not based upon any credible material but rather based upon
conjectures in the absence of any concrete findings.
8. The heart of the allegations leveled by the assessee against the
Revenue in this case is that ` 2,01,89,369/- deposited as TDS was not the
entire amount but that further amounts had in fact been deducted from the
salaries of no less than 31 pilots and unlawfully detained by it. The direction
of the enquiry was triggered by the complaints made by three individual
pilots and later by one Capt. Sandhu during the course of the proceedings.
The AO as well as CIT primarily went by the documents provided by the
three complainants, i.e. Capt. J.H. Patel, Capt. A.K. Vohra and Capt. S.C.
Mehta. The AO's order discusses the relevant details in respect of Capt. A.K.
Vohra alone. During the course of the AO's proceedings, the entire enquiry
was extended to include allegations leveled by one Capt. Sandhu. Basing
itself upon the conclusions and analysis arising out of the amounts
mentioned by the complainants, the AO found that over ` 67 lakhs was
payable as balance TDS that should have been deposited and a further sum in
excess of ` 60 lakhs was due as interest.
9. A careful reading of the AO's order would show that whilst the initial
part deals with allegations of one Capt. J.H. Patel, the only basis for
concluding that higher amounts were deducted from the salaries is premised
upon allegations leveled by Capt. A.K. Vohra. Capt. Vohra claimed that he
had worked for eight months in 1996 and that his gross salary was `
ITA 240/2004 Page 8 of 11
15,28,085/- out of which the amount deducted from his salary was `
6,15,980/- but that the Form 16 issued showed that his gross salary was
much lesser and the TDS too was ` 2,75,640/-. The assessee company's
stand was that the pilots were paid according to their individual contracts,
copies of which were made available to the Revenue. The assessee also
highlighted that each of the pilots had signed on Form 16 which signified the
actual amount paid and at no stage did they say that larger amounts were
deducted or that lesser amounts of salary was reflected but higher amounts
were paid. In other words, at the time of receiving the salaries and signing on
the documents which reflected the TDS, the alleged complainants never
stated that the documents reflected any incorrect picture. In the case of Capt.
B.S. Sandhu, the ITAT noticed that the tenor of his letter and his grievance
was that he was not paid salary for substantial periods, rather than
complaining that amounts lesser than what was deducted were in fact
deposited with the Revenue. As against this, significantly, in reply to the
summons issued to all pilots, under Section 131 of the Act, there was no
response. Furthermore, there was no attempt on the part of the Revenue to
reconcile the records as it were and verify whether in the individual tax
returns filed by the pilots, larger amounts were reflected. This failure, in the
opinion of the Court, cannot result in penalizing the assessee.
10. The ITAT's reasoning that the Revenue's findings were essentially
based upon conjectures and complaints rather than evidence or material is
reasonable and sound. The AO's order is primarily premised upon the
complaints of Capt. J.H. Patel and Capt. A.K. Vohra and a later letter
received from Capt. Sandhu. In their cases too, an attempt to reconcile
ITA 240/2004 Page 9 of 11
between the amounts declared by them in the tax returns and the amounts
shown in the returns and the TDS returns of the assessee, was never made.
These individuals too did not make their submissions or answer any reply to
the summons issued under Section 131 of the Act. The entire tenor of the
AO's order is accusatory and prosecutorial in requiring the assessee to
discharge almost a presumption that it had not paid the amounts. The AO
first had to establish the foundational fact that in respect of each of the 31
pilots, the amounts actually paid or deposited were less than the amounts
deducted from the salary. Such a determination had to be preceded by the
procedure known to law, i.e. in the form of show cause notice outlining the
exact amounts and the basis for such amounts. Instead the AO merely acted
upon the basis of some complaints and refused to look into all material
factors. There is no discussion for instance, as to the contractual amount in
the agreement signed by each pilot and the assessee; the AO has ignored the
important fact that no pilot joined the proceeding and answered summons
under Section 131 and most importantly, to reject the Form 24 furnished by
the assessee, mere complaints were insufficient. If the assessee's explanation
about lack of records due to fire seemed suspicious, nevertheless, the AO
was under a duty to cross-check and reconcile the returns filed by the
individual pilots from the concerned Wards and Circles before rendering its
findings. If there were facts that corroborating the allegations that larger
amounts were deducted but only a part thereof was in fact deposited with the
Revenue, then and then alone would the findings be justified. However, that
was not so in the circumstances of the case.
ITA 240/2004 Page 10 of 11
11. For the foregoing reasons, this Court is of the opinion that there is no
infirmity with the findings in the impugned order of the ITAT. The question
of law is answered in favor of the assessee and against the revenue. The
appeal accordingly fails and is dismissed.
S. RAVINDRA BHAT
(JUDGE)
SANJEEV SACHDEVA
(JUDGE)
JULY03, 2017
ITA 240/2004 Page 11 of 11
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NEW DELHI |
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150 |
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face='arial' color='#15c' size=2>Communication to the Central Excise/Service Tax Taxpayers on migration to GST |
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face='arial' color='#333333' size='2'> DIRECTORATE GENERAL OF SYSTEMS, CBEC |
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Communication to the Central Excise/Service Tax Taxpayers on migration to GST |
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Dear Central Excise/Service Tax Taxpayers, |
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Greetings from Central Board of Excise and Customs (CBEC). We thank you for your |
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duty/tax payments which have contributed to Nation building. |
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As you are aware...
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href='http://www.cainindia.org/news/7_2017/pr_commissioner_of_income_tax_vs_rmg_polyvinyl_i_ltd.html?tstst=59649f8092705&ntitle=Pr. Commissioner Of Income Tax Vs. Rmg Polyvinyl (I) Ltd' style='text-decoration:none'> |
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face='arial' color='#15c' size=2>Pr. Commissioner Of Income Tax Vs. Rmg Polyvinyl (I) Ltd |
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face='arial' color='#333333' size='2'>$~8 |
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* IN THE HIGH COURT OF DELHI AT NEW DELHI |
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+ ITA 29/2017 & CM No.1009/2017 |
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PR. COMMISSIONER OF INCOME TAX ..... Appellant |
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Through: Mr. Ruchir Bhatia, Mr. Puneet Rai & |
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Mr. Gaurav Khetrapal, Advocates. |
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versus |
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RMG POLYVINYL ...
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href='http://www.cainindia.org/news/7_2017/saras_metals_pvt_ltd_vs_commissioner_of_income_tax3_anr.html?tstst=59649f8092705&ntitle=Saras Metals Pvt. Ltd. Vs. Commissioner Of Income Tax-3 & Anr' style='text-decoration:none'> |
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face='arial' color='#15c' size=2>Saras Metals Pvt. Ltd. Vs. Commissioner Of Income Tax-3 & Anr |
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face='arial' color='#333333' size='2'>$~3 |
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* IN THE HIGH COURT OF DELHI AT NEW DELHI |
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+ ITA 251/2016 |
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SARAS METALS PVT. LTD. ..... Appellant |
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Through: Mr. Akhilesh Kumar, Arun Kumar Agarwal |
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& Mr. Akarsh Garg, Advocates. |
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versus |
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COMMISSIONER OF INCOME TA...
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href='http://www.cainindia.org/news/7_2017/housing_and_urban_development_corporation_limited_vs_additional_commissioner_of_income_tax_range_12.html?tstst=59649f8092705&ntitle=Housing And Urban Development Corporation Limited Vs. Additional Commissioner Of Income Tax Range 12' style='text-decoration:none'> |
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face='arial' color='#15c' size=2>Housing And Urban Development Corporation Limited Vs. Additional Commissioner Of Income Tax Range 12 |
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face='arial' color='#333333' size='2'>$~ |
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* IN THE HIGH COURT OF DELHI AT NEW DELHI |
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Reserved on: 9th May, 2017 |
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Pronounced on: 3rd July, 2017 |
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+ ITA Nos.440/2016, 442/2016, 444/2016, 445/2016 & 446/2016 |
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HOUSING AND URBAN DEVELOPMENT CORPO...
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href='http://www.cainindia.org/news/7_2017/know_your_tax_slab_before_filing_itr.html?tstst=59649f8092705&ntitle=Know your tax slab before filing ITR' style='text-decoration:none'> |
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face='arial' color='#15c' size=2>Know your tax slab before filing ITR |
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face='arial' color='#333333' size='2'>With less than a month left to file FY 2016-17 Income Tax Return (ITR) – the annual ritual – by individuals and other category of taxpayers, it becomes imperative that you have a clear idea about the tax slabs. |
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Much to the joy of the common man, Finance Minister Arun Jaitley during his Budget announcement this year reduced the existing...
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href='http://www.cainindia.org/news/7_2017/_mahavir_manakchand_bhansali_vs_cit_bombay_high_court.html?tstst=59649f8092705&ntitle= Mahavir Manakchand Bhansali vs. CIT (Bombay High Court)' style='text-decoration:none'> |
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face='arial' color='#15c' size=2> Mahavir Manakchand Bhansali vs. CIT (Bombay High Court) |
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face='arial' color='#333333' size='2'>S. 158BFA(1): If the delay in filing the return is completely attributable to the revenue for non-furnishing of copies of the documents and not giving inspection of the documents seized within a reasonable time after making the demand, the interest has to waived. Though s. 158BFA(1) does not (pre 2002) confer the power to waive interest, it has to ...
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href='http://www.cainindia.org/news/7_2017/more_complications_in_filing_income_tax_returns.html?tstst=59649f8092705&ntitle=More complications in filing income tax returns' style='text-decoration:none'> |
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face='arial' color='#15c' size=2>More complications in filing income tax returns |
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face='arial' color='#333333' size='2'>Until recently, a person didn’t need to file a return if his taxable income was below Rs 2.5 lakh. But this year onwards, it doesn’t solely depend on the taxable income. Now, if the taxpayer has exempted income like long-term capital gains that crosses the basic exemption limit of Rs 2.5 lakh, he needs to file returns mandatorily. ...
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href='http://www.cainindia.org/news/7_2017/new_opening_assistant_manager_accountsaccounts_officer.html?tstst=59649f8092705&ntitle=New Opening Assistant Manager - Accounts/accounts Officer' style='text-decoration:none'> |
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face='arial' color='#15c' size=2>New Opening Assistant Manager - Accounts/accounts Officer |
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face='arial' color='#333333' size='2'>Salary:INR 5,00,000 - 6,00,000 P.A.Industry:Accounting / FinanceFunctional Area:Accounts , Finance , Tax , Company Secretary , AuditRole Category:AccountsRole:Accounts ManagerUG: Any GraduatePG:Post Graduation Not RequiredContact Company:Somaiya Vidyavihar |
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...
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href='http://www.cainindia.org/news/7_2017/new_opening_assistant_general_manager_finance_accounts.html?tstst=59649f8092705&ntitle=New Opening Assistant General Manager - Finance & Accounts' style='text-decoration:none'> |
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face='arial' color='#15c' size=2>New Opening Assistant General Manager - Finance & Accounts |
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face='arial' color='#333333' size='2'>Salary:INR 10,00,000 - 17,00,000 P.A. Other Benefits as per company normsIndustry:Water Treatment / Waste ManagementFunctional Area:Accounts , Finance , Tax , Company Secretary , AuditRole Category:AccountsRole:Chartered AccountantPG:CARecruiter Name:GayatriContact Company:Ramky Enviro Engineers LtdAddress:SY No.136/2 AND 4, Ramky Grandiose13th flo...
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href='http://www.cainindia.org/news/7_2017/mergers_and_acquisitions_in_indian_banking_sector_not_threat_for_fintech_players.html?tstst=59649f8092705&ntitle=Mergers and Acquisitions in Indian banking sector not threat for fintech players' style='text-decoration:none'> |
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face='arial' color='#15c' size=2>Mergers and Acquisitions in Indian banking sector not threat for fintech players |
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face='arial' color='#333333' size='2'>The mergers and acquisitions (M&A) that may happen in the Indian banking sector may open up more opportunities for financial technology companies, said a top official of FIS-India. |
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The M&A may impact companies having CBS as their main product, but it is no longer the only source of truth for banks. |
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Incidentally, FIS had supplied CBS to Bh...
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href='http://www.cainindia.org/news/7_2017/centre_eases_premerger_filing_normsa.html?tstst=59649f8092705&ntitle=Centre eases pre-merger filing normsa' style='text-decoration:none'> |
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face='arial' color='#15c' size=2>Centre eases pre-merger filing normsa |
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face='arial' color='#333333' size='2'>In a move that is likely to boost mergers and acquisitions (M&A) in the country, the Centre has done away with the thirty-day time period to submit before the Competition Commission of India (CCI) an application for pre-merger clearance. |
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According to a notification on June 29 by the Ministry of Corporate Affairs (MCA), “the Central gover...
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href='http://www.cainindia.org/news/7_2017/oecd_releases_42_comments_on_transfer_pricing_guidance_for_hardtovalue_intangibles.html?tstst=59649f8092705&ntitle=OECD releases 42 comments on transfer pricing guidance for hard-to-value intangibles' style='text-decoration:none'> |
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face='arial' color='#15c' size=2>OECD releases 42 comments on transfer pricing guidance for hard-to-value intangibles |
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face='arial' color='#333333' size='2'>The OECD today released 42 comment letters responding to draft guidance that seeks to create a common method for tax administrations to implement Chapter VI of the OECD Transfer Pricing Guidelines regarding pricing hard-to-value intangibles. |
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The draft guidance, issued on May 23, allows tax administrations to consider ex post outcomes as evidence o...
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href='http://www.cainindia.org/news/7_2017/outlining_the_transfer_pricing_law_in_thailand.html?tstst=59649f8092705&ntitle=Outlining the transfer pricing law in Thailand' style='text-decoration:none'> |
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face='arial' color='#15c' size=2>Outlining the transfer pricing law in Thailand |
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face='arial' color='#333333' size='2'>This second draft of the laws, in general, aligns with the first draft released in May 2015, but provides further clarification on certain areas of concern, particularly on how to define “related party”, more details on the types of document that taxpayers need to prepare, timeline for disclosure and maintaining transfer pricing documen...
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href='http://www.cainindia.org/news/7_2017/gst_input_tax_credit_rules_how_taxpayers_will_benefit_from_itc.html?tstst=59649f8092705&ntitle=GST input tax credit rules: How taxpayers will benefit from ITC' style='text-decoration:none'> |
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face='arial' color='#15c' size=2>GST input tax credit rules: How taxpayers will benefit from ITC |
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face='arial' color='#333333' size='2'>The mechanism of input tax credit will ultimately reduce the final price to the wholesaler, retailer and consumer too, and cause a paradigm shift from individuals paying more taxes to more individuals paying taxes. |
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The change in indirect taxation regime from current taxation to GST (Goods and Services Tax) seems to be a game-changer reform. For co...
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href='http://www.cainindia.org/news/7_2017/income_tax_return_filing_10_common_mistakes_people_make_while_filing_return_of_income.html?tstst=59649f8092705&ntitle=Income Tax Return Filing: 10 common mistakes people make while filing return of income' style='text-decoration:none'> |
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face='arial' color='#15c' size=2>Income Tax Return Filing: 10 common mistakes people make while filing return of income |
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face='arial' color='#333333' size='2'>Income Tax Return Filing: While you are busy in collating your investment proofs and other information for filing for income tax return, you should take care to avoid the most common mistakes people make while filing the return of income. |
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Income Tax Return Filing: The due date of filing income tax return for the previous year 2016-17 (assessment y...
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href='http://www.cainindia.org/news/7_2017/rites_limited_vs_commissioner_of_income_tax_delhiv.html?tstst=59649f8092705&ntitle=RITES LIMITED Vs. COMMISSIONER OF INCOME TAX, DELHI-V' style='text-decoration:none'> |
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face='arial' color='#15c' size=2>RITES LIMITED Vs. COMMISSIONER OF INCOME TAX, DELHI-V |
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face='arial' color='#333333' size='2'>$~ |
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* IN THE HIGH COURT OF DELHI AT NEW DELHI |
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+ W.P.(C) 5331/2014 |
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Reserved on: 24th May, 2017 |
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Date of decision: 3rd July, 2017 |
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RITES LIMITED ..... Petitioner |
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T...
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color="#333333" size="2" face='arial'>For everyday detailed news update on ICAI, profession, latest judgments etc.; please visit at www.cainindia.org everyday.
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Best Regards,
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CAinINDIA Team
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www.cainindia.org
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