AI Insights
The case involves appeals by the Department against the orders passed by the CIT(A) which had deleted certain additions made by the Assessing Officer (AO) to the book profits of Suzlon Energy Ltd. for the assessment years 2012-13 and 2013-14. The main issues revolved around the disallowance of expenses under section 14A of the Income Tax Act, 1961, which were initially added back to the book profits under section 115JB. The Tribunal examined the precedents set in earlier years and similar cases, particularly focusing on the judgments of the ITAT and the jurisdictional High Court, which consistently favored the assessee on these grounds.
Appeal Details
Counselvise Citation
[2023] 140 COUNSELVISE.COM (IT) 133624 (ITAT-AHMEDABAD)
Assessee PAN
Bench
Appeal Number
CRN Number
Duration Of Justice
3 year(s) 10 month(s) 2 day(s)
Appellant
Respondent
Appeal Type
Cross Objection
Pronouncement Date
03-05-2023
Appeal Filed By
Assessee
Order Result
Dismissed
Bench Allotted
D
Next Hearing Date
08-02-2023
Assessment Year
2012-2013
Appeal Filed On
01-07-2019
Judgement Text
आयकर अपीलीय अिधकरण आयकर अपीलीय अिधकरणआयकर अपीलीय अिधकरण आयकर अपीलीय अिधकरण, अहमदाबाद 瀈यायपीठ अहमदाबाद 瀈यायपीठअहमदाबाद 瀈यायपीठ अहमदाबाद 瀈यायपीठ ‘D’ अहमदाबाद। अहमदाबाद।अहमदाबाद। अहमदाबाद। IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, AHMEDABAD BEFORE SMT.ANNAPURNA GUPTA, ACCOUNTANT MEMBER AND SHRI SIDDHARTHA NAUTIYAL, JUDICIAL MEMBER ITA No.970/Ahd/2018 [Asst.Year : 2012-13] WITH Cross Objection No.100/Ahd/2019 AND ITA No.971/Ahd/2018 AsstYear : 2013-14 DCIT, Cir.4(1)(1) Ahmedabad. Suzlon Energy Ltd. Suzlon-5 Shrimali Society Nr.Shri Krishna Centre Navrangpura Ahmedabad 380 015. PAN : AADCS 0472 N (Applicant) (Responent) Assessee by : Shri Tushar Hemani, Sr.Advocate Shri Parimalsinh B. Parmar Revenue by : Shri SudhenduDas,CIT-DR स ु नवाई क तार ख/Date of Hearing : 09/02/2023 घोषणा क तार ख /Date of Pronouncement: 04/05/2023 आदेश/O R D E R PER ANNAPURNA GUPTA, ACCOUNTANT MEMBER These are two appeals by the Department against orders passed by the ld. Commissioner of Income Tax (Appeals)-8, Ahmedabad[hereinafter referred to as “Ld.CIT”] dated 02.02.2018 ITA No.970 & 971/Ahd/2018 with CO 2 and 14.2.2018 pertaining to the Asst.Year 2012.13 and 2013-14 under section 250(6) of the Income Tax Act, 1961 (hereinafter referred to as the “Act’ for short). The assessee has also filed cross objection bearing no.100/Ahd/2019 in Revenue’s appeal for Asst.Year 2012-13. Since issues raised in both the appeals of the Revenue admittedly are identical arising from common facts, we proceed to dispose of both the appeals and CO by this single order for the sake of convenience. 2. We shall be dealing with the facts in the case of the department’s appeal for Asst.Year 2012-13 in ITA No.970/Ahd/2018 and our decisions rendered therein will apply pari passu in other appeal of the Department for Asst.Year 2013-14,in ITA No.971/Ahd/18 where facts and issues are stated to be identical. ITA No.970/Ahd/2018 : A.Y 2012-13 (Revenues appeal) 3. Ground No.1 raised by the Revenue is as under: “1. That the ld.CIT(A) has erred in law and on facts in deleting the addition amounting to Rs.20,45,90,906/- made on account of disallowance u/s.14A of the Income Tax Act, 1961 in book profits u/s.115JB of the Act. 4. As is evident from the above, the issue relates to the adjustment made to the book profits of the assessee calculated as per the provisions of section 115JB of the Act. The adjustment made relates to addition made to the Book Profits of the expenses incurred for the purpose of earning exempt income which were disallowed asper the provisions of section 14A of the Act. The assessee had made a suo moto disallowance of a sumof Rs.20,45,90,406/- under section 14A of the Act calculated as per the formula prescribed in Rule 8D of the Income Tax Rules, 1962. ITA No.970 & 971/Ahd/2018 with CO 3 However, the same was not added back while calculating the book profits under section 115JB of the Act. The AO accordingly added back this sum to the book profit of the assessee under section 115JB of the Act, which was deleted by the ld.CIT(A) noting that identical adjustment of expenses disallowed under section 14A of the Act to the book profit of the assessee was deleted by the ITAT in the case of the assessee itself in earlier year i.eAsst.Year 2010-11. The relevant finding of the ld.CIT(A) at para 4.3 of his order is as under: “4.3 Decision: I have considered the facts of the case, submissions made by the appellant and the Assessment Order. The appellant while filing the return of income suo motu disallowed a sum of Rs.20,45,90,4067-u/s 14A computed as per formula provided in Rule 8D of the Income Tax Rules, 1962. However, the same was not added to the book profit u/s 115JB of the Act. I find that an identical issue was decided in the Appellant's own case for A.Y 2010-11 by the Hon'ble ITAT , Ahmedabad in ITA No. 2791 & 2530/Ahd 72014 , wherein the issue was decided in favour of the Appellant by following the judgement in appellant's own case in AY 2009-10 . Relevant excerpts of the judgement are reproduced as below : " 12. Ground No. 3 relates to the deletion of the positive adjustment u/s.14A while determining book profit u/s. 11'5JB of the Act. 13. While deciding the appeal for A.Y.2009-10, the Tribunal has considered this issue at para 38 while deciding ground no 7 of Revenue's appeal wherein the co-ordinate Bench has decided the issue in favour of the assesssee by drawing support from the decision of the Hon'ble High Court of Gujarat in the case of Alembic Ltd. in ITA No. 1249 of 2014." 4.2 Respectfully following the said order and judgments of the jurisdictional High Court in the case of M/s. Alembic Limited (Supra), I hold that the disallowance u/s 14A of the Act cannot be added to book profits calculated u/s 115JB of the Act. Thus, Ground No. 1 of the appeal is allowed”. 5. The ld.DR was unable to controvert the finding of theld.CIT(A) as above that the issue stood adjudicated in favour of the assessee by the ITAT in the case of the assessee itself in earlier year. He could not bring to our notice any decision of Hon’ble High Court upturning the decision of the ITAT in the case of the assessee itself or any other cases; nor was he able to distinguish the case of the assessee from the decision of Hon’ble Gujarat High Court in thecase ITA No.970 & 971/Ahd/2018 with CO 4 of case of Alembic Ltd. in ITANo.1249 of 2014, which followed by the ITAT in the preceding year while deleting identical adjustment of expenses disallowed under section 14A of the Act to the book profits of the assessee. 6. The ld.counsel for the assessee, on the other hand, filed submissions before us pointing out that the ITAThad not only deleted the identical disallowance in the case of the assessment in Asst.Year 2010-11, but it had consistently taken this view in Asst.Year 2009-10, 2011-12 and even Asst.Year 2015-16. Copies of all the orders of the ITAT in the case of the assessee for the said years were placed before us. It was also contended that the issue of adjustment to bookprofits on account of disallowance of expenses under section 14A of the Act is settled in view of the decision of Hon’ble jurisdictional High Court in the case of Alembic Ltd. (supra) and by the decision of the Special Bench of the ITAT in the case of ACIT Vs. Vireet Investment P.Ltd., (2017) 165 ITD 27 (Delhi-Trib) (SB). 7. In view of the above, since ITAThas been consistently deleting the adjustment made to the book profits under section 115JB of the Act on account of disallowance of expenses as per the provision of section 14A of the Act in the case of the assessee itself right from AY 2009-10 TO 2011-12 and even in Asst.Year2015-16 considering the decision of the jurisdictional High Court in the case of Alembic Ltd. (supra) and the decision of the Special Bench of the ITAT in the case of Vireet Investment P.Ltd., and the fact that the ld.DR being unable to distinguish the decisions cited (supra) to the facts of the present, we see no reason to interfere in the order of the ld.CIT(A) deleting the adjustment made to the book profits of the assessee on account of expenses disallowed under section 14A of the Act amounting to ITA No.970 & 971/Ahd/2018 with CO 5 Rs.20,45,90,406/- following the consistent view taken by the ITAT in this regard in the case of the assessee itself, and the decisionof the jurisdictional High Court on the same. Thus, ground no.1 raised by the Revenue stands dismissed. 8. Now we take ground no.2 of the Revenue as under: “2. That the ld.CIT(A) has erred in law and on facts in deleting the addition amounting to Rs.4,15,67,693/- made on account of upward adjustment u/s.92CA(3) of the Income Tax Act, 1961” 9. As is evident from the above the issue raised in the above ground relates to upward adjustment of Rs.4,15,67,693/- made by the AO while determining arm’s length price (ALP) of international transactions undertaken by the assessee, in terms of the Transfer Pricing provisions of the Act.The facts relating to the issue, as emanates from the order of the ld.CIT(A), is that the assessee had entered into international transactions with its associate enterprise (AE) and also filed report in Form no.3CEB under Rule 10E of the IT Rules. Thatafter obtaining the approval of the Ld.Pr.CIT, the AO had referred the case to the TPO who in turn suggested upward adjustment amounting to Rs.4,15,67,693/- towards the following amounts: i) Guarantee fee attributed to the cost of guarantees given to various banks on behalf of its AEs : Rs.3,97,66,646/-; ii) Guarantee fees attributed to fresh guarantees extended in favour of Exim Bank of India for its AEs - : Rs.18,01,047/- 10. This upward adjustment suggested by the TPO was confronted by the AO to the assessee, who indicated that he did not wish to contest these additions before the Dispute Resolution Panel, and accordingly, the AO made upward adjustment on account of the ITA No.970 & 971/Ahd/2018 with CO 6 amounts, totaling to Rs.4,15,67,693/-. The addition was agitated by the assessee before the ld.CIT(A) who noted from the TPO’s order that the assessee had given corporate guarantees to various banks on behalf of its AEs. As per the TPO this tantamounted to risk taken on behalf of the AEs with respect to loan value and he noted that the assessee had charged no guarantee fee for the same. The TPO asserted that had the guarantee been given on behalf of unrelated persons, the assessee would certainly have charged guarantee fee, and finding that commercial bank charged guarantee fees ranging from 0.75% to 2% on the collateral security provided by the client, and noting that in the present case AEs had not provided any collateral securities to the assessee, the TPO suggested ALP of guarantee fee at the rate of 2% of the guarantees expenditure, and accordingly, an upward adjustment of Rs.4,15,67,693/- was made. The ld.CIT(A) however deleted the adjustment noting that the issue was squarely covered in favour of the assessee by the decision of the ITAT in the case of the assessee itself in the preceding year i.e.Asst.Year 2008-09, 2009-10 and 2010-11. The relevant finding of the ld.CIT(A) at para 7.4 of his order is as under: “7.4 Decision: I find that the issue is squarely covered in the appellant's own case in favour of the appellant by the judgment of Hon'ble ITAT, Ahmedabad in A.Y.2008-09, 2009-10 & 2010-11. The judgment of Hon'ble ITAT in the asessee's own case in A.Y.2009-10 was delivered on 22/12/2017 in ITA No.2074/Ahd/2013 wherein the Honb'le Bench taking note of the issue pending with jurisdictional High Court in the case of Micro Ink Ltd. [2015] 63 taxmann.com 353 (Ahmedabad- Trib.) have allowed the assessee's appeal following their earlier judgments in asessee's own case in relation to A.Y.2008-09, order dated 21/04/2017. The relevant excerpts of the judgment are reproduced as below: "6. We see no reasons to take any other view of the matter that the view so taken, by the co-ordinate bench, for the immediately preceding assessment year. We, therefore, uphold the grievance of the assessee and delete the impugned ALP adjustments. ITA No.970 & 971/Ahd/2018 with CO 7 Following the judgments of Hon'ble ITAT in appellant's own case (supra) the upward adjustment in the ALP (Arms Length Price) amounting to Rs.4,15,67,693/- is deleted. Thus, ground No. 4 & 5 are allowed.” 11. Before us, the ld.counsel for the assessee pointed out that this issue was consistently decided in favour of the assessee by the ITAT right from Asst.Year 2008-09 to 2011-12 and even in Asst.Year 2015-16. Copies of all these orders were placed before us. It was also pointed out that the issue was covered by the decision of the ITAT in the case of Micro Ink Vs. ACIT, (2016) 157 ITD 132 (Ahd- Trib) wherein it was held that the issuance of corporate guarantee did not constitute international transactions and no TP adjustment is liable to made. 12. The ld.DR was unable to controvert the facts as noted by the ld.CIT(A) nor was he able to draw the attention to any distinguishing facts from the preceding year or from the case of Micro Ink (supra). In view of the above, we see no reason to interfere in the order of the ld.CIT(A) deleting upward adjustment ofRs.4,15,67,693/- made as per the TP provisions on account of corporate guarantee fees to be charged by the assessee from its AE. Ground No.2 is accordingly dismissed. 13. In the result, the appeal of the Revenue for Asst.Year 2012-13 is dismissed. 14. We now take cross objection filed by the assessee. 15. CO No.100/Ahd/2019 16. The grounds raised in the CO are as under: “1. The learned CIT(A) has erred both in law and on the facts of the case in confirming the action of the AO of disallowing employee's contribution ITA No.970 & 971/Ahd/2018 with CO 8 towards PF and ESIC amounting to Rs.29,94,862/- u/s 36(l)(va) r.w.s.2(24)(x) of the Act. 2. The learned CIT(A) has failed to appreciate that the entire sum in respect of employees contribution to PF/ESIC has been deposited prior to the due date of filing return of income and hence, the appellant is entitled for deduction as per s.43B of the Act. 3. Alternatively and without prejudice to the above, the matter should be remanded to the AO to verify whether the sum was deposited within 21 days from the end of the month of payment of salary as contemplated under the provisions of Employees Provident Funds & Miscellaneous Provisions Act, 1952 and Employees State Insurance Act, 1948. 17. The only issue raised by the assessee in its CO is relating to confirmationof addition made by the AO under section 36(1)(va) of the Act on account of delayed payment of employees’ contribution to PF and ESI funds; the total amount disallowed pertaining to the same is Rs.29,94,862/-; being Rs.17,63,251/- on account of delayed payment of employees’ contribution to PF and Rs.12,31,611/- on account of delayed payment employees’ contribution to ESI fund. 18. The ld.counsel for the assessee was unable to controvert the facts relating to the case that the employees’ contribution to both the ESI and PF was delayed and paid beyond the due dates prescribed as per the respective Acts. In view of the above, the assessee, we hold, has no merit in its case, since the issue stands settled and decided against the assessee in view of the decision by the Hon’ble Apex Court in the case of Checkmate Services P.Ltd. Vs. CIT, 143 taxmann.com 178 (SC) dated 12.10.2022 wherein it has been held that the provision of section 36(1)(va) of the Act warrants addition to the income of the assessee to the extent of amount so delayed to be deposited in the relevant funds. The ground no.1 and 2 raised by the assessee are accordingly dismissed. ITA No.970 & 971/Ahd/2018 with CO 9 19. In the result, the CO of the assessee is dismissed. We shall now take up the Revenues appeal for A.Y 2013-14. 20. ITA No.971/Ahd/2018: A.Y 2013-14 (Revenue’s appeal) 21. Ground No.1 and 2 of the appeal read as under: 1. "that the Id. CIT (Appeals) has erred in law and on facts in restricting the voluntary disallowance made by the assessee itself in its return of income at Rs.31,40,76,653/- u/s. 14A of the Income Tax Act, 1961, to the extent of the exempt income claimed by the assesseei.e. 2,16,251/-." 2. that the Id. CIT (Appeals) erred in law and on facts in not appreciating that there is no requirement in law for earning of exempt income to make disallowance u/s. 14A r. w. rule 8D, and the same is reiterated in CBDT Circular No. 5 of 2014." 22. The issue raised in the above grounds relates to disallowance of expenditure incurred for the purpose of earning exempt income as per section 14A of the Act which was restricted by the ld.CIT(A) to the extent of exempt income earned by the assessee amounting to Rs.2,16,251/-. The relevant finding of theld.CIT(A) in this regard at para 5 of the order is as under: “5. Decision: I have carefully considered the facts of the case, submissions made by the appellant and gone through the judgments relied upon. Appellant's case is that (a) since during the year it has more free reserves than the investments made the interest component as provided in formula under Rule 8D of Income Tax Rule's, 1962 (the Rules) cannot be attributed to earning of exempt income and also since it has claimed exempt income only to the extent of Rs.2,16,251/-, the disallowance u/s 14A of the Act could not have exceeded the amount of exempt income as per the ratio of judgment of Hon'ble Gujarat High Court in the case of Corrtech energy Ltd. (supra) as well as, as per the judgment of Hon'ble Ahmedabad Tribunal in the case of Jivraj Tea (Supra), (b) since it has wrongly disallowed a sum of Rs.31,40,76,6537- in the computation of income u/s.14A. AO should have acceded to their claim of withdrawal of the disallowance and (c) disallowance computed u/s.14A r.w.r. 8D cannot be added to the book profits computed as per provisions of section 115JB(2). 4.1.1. As regards the ground that disallowance u/s.14A r.w.r. 8D cannot exceed the exempt income, I find that the issue is squarely covered by the ratio of this judgment of the jurisdictional High Court in the case of M/s. Corrtech Energy Ltd. (supra). Now, the issue is whether appellant having made the disallowance suo-motu can claim reduction in the returned income to the extent of this disallowance before the assessing authority or appellate ITA No.970 & 971/Ahd/2018 with CO 10 authorities. This is undisputed fact that appellant computed the disallowance as per section 14A of the Act r.w.r. 8D of the Rules. In this regard appellant has placed reliance on various judgments as noted in para 4.1 above. In the case of CIT-'I v. Arvind Mills Ltd., the Hon'ble High Court of Gujarat has dealt with the issue and held the following: . " 4. As the facts on record show that the AO himself had found the claim of the assessee to be genuine. He did not grant relief on the basis that the claim could have been considered only on filing of a revised return. The appellate commissioner on the basis of the Supreme Court decision in Ajanta (supra)allowed the claim which was admittedly a genuine one and tribunal ultimately upheld the same. 5. As such in Goetze (supra) the Supreme Court while dismissing the appeal clarified that its decision was restricted to the power of Assessing Officer to entertain claim for deduction otherwise than by a revised return, and did not impinge on the powers of the Assessing authority u/s.254 of the Act. 6. When the claim of the assessee was genuine and acceptable on merit, the appellate commissioner acted within its power and rightly allowed the same. That was confirmed by the tribunal. In that view, the impugned order of the tribunal warrant no interference. No substantial question of law arising for consideration." 4.1.2 With these observations, the Hon'ble Court dismissed the appeal of the revenue. Appellant had further relied on the case of CIT-4 v. Symphony Comforts System Ltd. Tax Appeal No.97 of 2007. In this case one of the issue before the Hon'ble High Court of Gujarat was that during the course of assessment proceedings, assessee contended before the AO that due to oversight interest payable on cash credit amount with State Bank of India was disallowed u/s.43B of the Act by the assessee even though the cash credit amount was not covered - u/s.43B of the Act. Therefore, assessee requested for deduction of the amount of Rs.1,18,53,407/- which was wrongly disallowed by it u/s.43B of the Act. The Hon'ble High Court allowed the appeal of the assessee. further, assesse has relied on the case of Pr. Cit-4 v. Zydus Wellness Ltd, wherein the Hon'ble Gujarat High Court has held the following: Having heard learned learned counsel for the parties and having perused the orders on record, we see no reason to interfere. The issue of tenability of a claim though not raised in the original return is examined by the Courts in various decisions. This Court in case of CIT v. Miteshlmpex[2014l 46 taxmann.com 30/225 Taxman 168 (Mag.) (Guj.) Preferred to and relied on several judgements of the Supreme Court and High Courts including the judgement of Bombay High Court in case of Pruthvi Brokers & Shareholders P. Ltd. (sura) and observed as under: "38. It thus becomes clear that the decision of the Supreme Court in the case of Goetze (India) Ltd. v. Commissioner of Income-tax (supra) is confined to the powers of the assessing ITA No.970 & 971/Ahd/2018 with CO 11 officer and accepting a claim without revised return. This is what Supreme Court observed in the said judgment while distinguishing the judgment in the case of National Thermal Power Co. Ltd. v. Commissioner of Income-tax (supra) and that is how various High Courts have viewed the dictum of the decision in the case of Goetze (India) Ltd. v. Commissioner of Income-tax (supra). When it comes to the power of Appellate Commissioner or the Tribunal, the Courts have recognized their jurisdiction to entertain a new ground or a legal contention. A ground would have a reference to an argument touching question of fact or a question of law or mixed question of law or facts. A legal contention would ordinarily be a pure question of law without raising any dispute about the facts. Not only such additional ground or contention, the Courts have also, as noted above, recognized the powers of the Appellate Commissioner and the Tribunal to entertain a new claim for the first time though not made before the assessing officer. Income Tax proceedings are not strictly speaking adversarial in nature and the intention of the Revenue would be to tax real income. 39. This is primarily on the premise that if a claim though available in law. is not made either inadvertently or on account of erroneous belief of complex legal position, such claim cannot be shut out for all times to come, merely because it is raised for the first time before the appellate authority without resorting to revising the return before the assessing officer." . . 4.1.3 The facts of this case are exactly similar to the cases referred to hereinabove. In all the cases the Hon'ble Courts have held that if the claim made by the assessee before the appellate authorities which was also a subject matter before the AO has to be allowed if on merit the same is allowable. In this case, appellant has suo motu calculated the disallowance u./s.14A even though such disallowance is not warranted to the extend it exceeded the exempt income, coupled with the fact that the appellant as own funds more than the investments made in exempt income yielding instruments. Respectfully following the above judgments including the judgment of jurisdictional High Court I find that the claim of the appellant is allowable and accordingly AO is directed to restrict the disallowance to the extent of the exempt income claimed.” 23. As is evident from the above, the ld.CIT(A) had restricted the disallowance to extent of exempt income earned by following the decision of jurisdictional High Court in the case of CIT Vs.Corrtech Energy Ld., 372 ITR 97. Since the ld.DR was unable to distinguish the said case before us, nor was he brought to our notice any contrary decisions of Hon’ble jurisdictional High Court or of the Apex Court, we see no reasons to interfere in the order of the ld.CIT(A) ITA No.970 & 971/Ahd/2018 with CO 12 restricting the disallowance of expenditure under section 14A of the Act to the extent of exempt income earned by the assessee amounting to Rs.2,16,251/-. Thus, ground no.1 and 2 raised by the Revenue are dismissed. 24. Ground No.3 reads as under: “that the ld.CIT(A) has erred in law and on facts in deleting the addition amounting to Rs.31,40,76,653/- made on account of disallowance u/s.14A of the Income Tax Act, 1961 in book profit u/s.115JB of the Income Tax Act, 1961.” The issue raised in Ground No.3, it was common ground, was identical to that raised in ground no.1 of Revenues appeal for the preceding year, A.Y 2012-13, in ITA No.970/Ahd/2018 , relating to addition made to book profits of the assessee, as per section 115JB of the Act, of expenses disallowed under section 14A of the Act amounting to Rs.31,40,76,653/-. 25. We have dealt with this issue in para-7 of our order above, dismissing the ground raised by the Revenue. Following the same, this ground of appeal No.3is dismissed. 26. Ground No.4 reads as under: “that the ld.CIT(A) has erred in law and on facts in deleting the addition amounting to Rs.6,77,95,312/- made on account of upward adjustment u/s.92CA(4) of the of the Income Tax Act, 1961.” The issue raised in Ground No.4, it was common ground, was identical to that raised in ground no.2 of Revenues appeal for the preceding year, A.Y 2012-13, in ITA No.970/Ahd/2018 which has been dealt with at para-9 to 12 of our order above rejecting the ITA No.970 & 971/Ahd/2018 with CO 13 ground raised by the Revenue. For the same reasons and observations, we also dismiss this ground no.4 of the Revenue. 27. In the result, the appeal of the Revenue is dismissed. 28. In the combined result, the appeals of the Revenue and CO of the assessee are dismissed. Order pronounced in the Court on 4 th May, 2023 at Ahmedabad. Sd- Sd/- (SIDDHARTHA NAUTIYAL) JUDICIAL MEMBER (ANNAPURNA GUPTA) ACCOUNTANT MEMBER Ahmedabad,dated 04/05/2023 vk*
Other Referred Cases
Alembic Ltd. vs. ITA No.1249 of 2014, ACIT vs. Vireet Investment P.Ltd., (2017) 165 ITD 27 (Delhi-Trib) (SB), Micro Ink vs. ACIT, (2016) 157 ITD 132 (Ahd- Trib), Checkmate Services P.Ltd. vs. CIT, 143 taxmann.com 178 (SC), CIT vs. Corrtech Energy Ltd., 372 ITR 97, CIT-'I vs. Arvind Mills Ltd., CIT-4 vs. Symphony Comforts System Ltd., Pr. Cit-4 vs. Zydus Wellness Ltd.
Laws Referred To
Income Tax Act, 1961
1:1 Consultation on Business Valuations
₹1
Consultation on Entity Formation
₹0
1:1 Consultation on SME Listing
₹0
Object Clause - Merchant Banking Business
Mehul₹100
Memorandum of Understanding - Relevant for Revenue Sharing between Companies
Mehul₹500
When Global Talent Meets GST: The Huawei Secondment Ruling explained
Team Counselvise - March 09, 2026
Finance Bill, 2026: Key GST Reforms that will Reshape Compliance and Cash Flows
Team Counselvise - February 03, 2026
Budget 2026: 5 Major Personal Tax Changes Every Taxpayer Must Know
Team Counselvise - February 05, 2026