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SC Upholds ITAT Remand in Transfer Pricing Dispute on Intra-Group Services

September 19, 2025 768 Views 0 comment Print

Supreme Court dismissed the SLP, affirming that ITAT rightly remanded the case to TPO to reassess ALP of intra-group services, stressing that Section 92C(3) conditions must be examined before adjustments.

EDC Payments to HUDA Not Liable for Section 194A TDS: ITAT Delhi

September 19, 2025 462 Views 0 comment Print

Tribunal held that EDC paid to HUDA is a statutory levy and not interest, quashing disallowance u/s 40(a)(ia) based on erroneous application of Section 194A.

Consultant Doctors Not Employees: TDS to Be Deducted Under Section 194J

September 19, 2025 717 Views 0 comment Print

Bombay High Court ruled on TDS for Nanavati Hospital. It confirmed doctors are independent professionals, but remanded the AMC matter for re-evaluation.

No Fair ALP Without Upper Turnover Cap in TP Comparables ITAT Cochin

September 15, 2025 471 Views 0 comment Print

ITAT directs fresh transfer pricing analysis for UST Global, ruling that tax authorities must apply an upper turnover filter when using a lower one.

Delhi HC Affirms disallowance of delayed Employees’ PF/ESI Contributions

September 13, 2025 651 Views 0 comment Print

Delhi HC confirms PF/ESI delay disallowance under Sec 143(1). Employee contributions must be deposited by due dates to qualify for tax deductions.

No Sec. 201 default for foreign remittances when payees paid tax: ITAT Mumbai

September 9, 2025 396 Views 0 comment Print

ITAT Mumbai rules SBI is not an assessee in default for TDS on foreign remittances if payees have paid taxes. Explains implications for MasterCard, Visa, and interest liability.

Bombay HC: No Disclosure Failure, No Reopening After 4 Years

September 5, 2025 390 Views 0 comment Print

Bombay High Court rules against the Income Tax Department, stating that a reassessment notice issued after 4 years is invalid without a clear allegation of the assessee’s failure to disclose material facts.

ITAT Chennai Quashes Income Tax Assessment on Non-Existent Company

September 4, 2025 387 Views 0 comment Print

The ITAT quashed a final assessment order against a company that no longer existed due to amalgamation, ruling the order void despite departmental knowledge of the merger.

ITAT Quashes Assessment on Revenue’s failure to provide jurisdictional order

September 4, 2025 507 Views 0 comment Print

The ITAT quashed an assessment against Karan Motors, ruling it was void because the Income Tax Department failed to prove the ACIT’s jurisdiction to act as the Assessing Officer.

MLI provisions unenforceable sans separate notification: ITAT Mumbai

September 3, 2025 744 Views 0 comment Print

The Mumbai ITAT ruled that MLI provisions cannot be applied to deny treaty benefits under the India–Ireland DTAA without a specific notification under Section 90(1) of the Income Tax Act.

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