Direct Tax

Compensation paid for delayed allotment of plot of land is not interest. No TDS u/s 194A.

Sawhney Builders (P.) Ltd. v. ACIT (TDS) – [2023] 151 taxmann.com 97 (Delhi-Trib.).

CBDT amends IT Rules to incorporate Finance Act 2023 amendments related to trusts & institutions.

Notification No. 45/2023, dated 23-6-2023.

CBDT amends Income-tax Rules as per new tax regime; notifies Rule 21AGA and Form 10-IEA to opt for old tax regime.

Notification No. 43/2023/F. No. 370142/15/2023-24 – TPL, dated 21-6-2023.

CBDT notifies scope of e-Appeal Scheme, 2023; outlines its exclusions.

Notification No. F. No. 370149/97/2023 – TPL, dated 16-6-2023.

Customs Valuation would yield a more reliable result for TP if there is no difference in contract terms and product quality.

Louis Dreyfus Company India (P.) Ltd. v. DCIT – [2023] 150 taxmann.com 392 (Delhi-Trib.).

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).