Delhi ITAT ruled that only unique solar days of employee presence, and not cumulative man-days, should be considered for determining Service PE under the India-US DTAA. Since the assessee’s employees stayed only 72 unique days in India, no PE existed and Section 44BB taxation was deleted.
The new Income Tax Act, 2025 significantly reduces the number of statutory sections and reorganises tax compliance procedures effective from FY 2026-27. The reforms introduce new forms, revised reporting systems, and simplified compliance mechanisms.
The new law keeps depreciation methods unchanged for continuity. However, it broadens tax scope by including assets “belonging to” taxpayers beyond legal ownership.
The policy limits AI to administrative and research roles while prohibiting its use in judgments or legal reasoning. It reinforces that judges must retain full responsibility for decisions to preserve fairness and constitutional values.
The Tribunal ruled that a Dependent Agent PE arises only if agents habitually conclude contracts or secure orders on behalf of the foreign enterprise. Since no such evidence existed, the foreign company’s income from software sales was not taxable in India.
The government allowed investments with up to 10% non-controlling beneficial ownership through the automatic route, easing restrictions imposed under Press Note 3 while retaining safeguards.
Goa notifies 30 June 2026 as deadline to file GST Appellate Tribunal appeals for orders communicated before 1 April 2026 under Section 112 of the Goa GST Act.
Goa extends the appeal filing deadline to June 30, 2026, for earlier orders. The move ensures taxpayers get adequate time while maintaining standard timelines for new cases.
The High Court held that only 30 days of limitation survived after applying TOLA and Supreme Court rulings. Notices issued after expiry of the surviving period were declared time-barred.
Setting aside the assessment, the Court held that non-selection of a portal option cannot deprive an assessee of oral hearing. Denial of such opportunity amounted to violation of natural justice.
