Learn about the case of Skybridge Solutions Private Limited vs. DCIT (ITAT Hyderabad) regarding the final assessment order passed under Section 144C without objection against the draft assessment order. Understand the implications and key takeaways from the judgment.
Sub-section (8) of section 154 specifies that rectification application under this section need to be disposed off in a time bound manner (i.e. six months from the end of the month in which application is received).
The Hon’ble ITAT deleted the transfer pricing adjustment on account of interest on receivables due to failure of revenue authorities to find out even a single comparable in assessee’s segment charging interest in uncontrolled market conditions.
It has held that difference in the level of capacity utilization is an accepted principle, though denied in the relevant AY to the respondent. The same cannot, however, tantamount to filing without good faith and due diligence.
JRS Pharma and Gujarat Microwax Private Limited Vs DCIT (Gujarat High Court) Question of law: whether the revenue is justified in reopening the assessment for the year under consideration? Writ application filed before the Hon’ble HC of Gujrat challenging notice u/s 148 of the Income Tax Act, 1961 for reopening the assessment for AY 2013-14. […]
The Double Taxation Avoidance Agreement (DTAA), inter alia, provide rules and mechanisms for allocation of taxing rights amongst the treaty partners; avoidance of economic and juridical double taxation; and resolution of taxation not in accordance with the treaty through the Mutual Agreement Procedure (‘MAP’). MAP is an inbuilt and alternate tax dispute resolution mechanism available to the taxpayers under the DTAAs. It is […]
The Finance Act, 2009 introduced with effect from 01.10.2009 an alternate dispute resolution mechanism to facilitate expeditious resolution of disputes in tax related matters for foreign companies and for transfer pricing matters.