Re-assessment – SLP dismissed against order of HC that where issues of foreign remittances, related to reimbursement of employee cost by assessee to its foreign subsidiaries was under active consideration of AO in assessment proceedings, and only because in succeeding assessment years, AO had come to a different opinion, impugned notice passed for re-assessment on ground that issue was not specifically dealt with in original assessment would be a mere change of opinion and not sustainable.
ACIT v. Oracle Financial Services Software Ltd. – [2023] 150 taxmann.com 445 (SC).
Sec. 194J – Sum paid to contract teachers cannot be treated as ‘fee for professional services’, TDS u/s 194J does not apply.
Dist. Intermediate Educational Office v. ITO – [2023] 150 taxmann.com 439 (Hyd. – Trib.).
Govt. notifies Sovereign Gold Bond Scheme 2023-24.
Notification No. G.S.R. 438(E), dated 14-6-2023.
CBDT notifies JCIT(A) / Addl. CIT(A) to facilitate conduct of e-appeal proceedings.
Notification No. S.O. 2624(E), dated 14-6-2023.
Section 40A(2) – AO cannot invoke this section without demonstrating how he formed opinion that expenses were excessive and unreasonable.
Technip Energies Italy SPA v. DCIT – [2023] 150 taxmann.com 525 (Delhi-Trib.).
ITR not filed in time as CA was discharging family obligations is ‘genuine hardship’; delay of 36 days to be condoned.
ADCC Infocom (P.) Ltd. v. PCCIT – [2023] 150 taxmann.com 529 (Bombay).