Income Tax : Taxpayers face challenges when assessment orders don’t reflect DRP directions. Misalignments lead to disputes, rectification iss...
Income Tax : The legal community awaits the Supreme Court decision on the Roca Bathroom case, addressing timelines for transfer pricing assessm...
Income Tax : Discover how Section 44C of the Income Tax Act, 1961, governs the deduction of head office expenses for non-resident businesses in...
Income Tax : ITAT Ahmedabad held that that the activities / services do not qualify as stewardship / shareholder activity. Further, assessee co...
Income Tax : Delhi High Court held that order issued u/s. 143(3) of the Income Tax Act wrongly challenged on the assumption that it is draft as...
Income Tax : Analysis of Hyundai Rotem Vs ACIT case by ITAT Delhi on tax assessments, time limits under Section 144C, and procedural compliance...
Income Tax : The application preferred by the petitioner for recall of the said order was also rejected by the Supreme Court vide order dated 2...
Income Tax : ITAT Bangalore held that when the reasons supplied to the assessee and the reasons supplied before higher forum is not verbatim sa...
ITAT Ahmedabad held that that the activities / services do not qualify as stewardship / shareholder activity. Further, assessee correctly determined Arm’s Length Price in respect of management fees by using Transaction Net Margin Method i.e. TNMM.
Delhi High Court held that order issued u/s. 143(3) of the Income Tax Act wrongly challenged on the assumption that it is draft assessment order u/s. 144C is untenable in law. Accordingly, cost of ₹1,00,000/- imposed on petitioner.
Analysis of Hyundai Rotem Vs ACIT case by ITAT Delhi on tax assessments, time limits under Section 144C, and procedural compliance for international taxation cases.
The application preferred by the petitioner for recall of the said order was also rejected by the Supreme Court vide order dated 25.10.2019. It is thereafter that petitioner-assessee preferred a review petition.
ITAT Bangalore held that when the reasons supplied to the assessee and the reasons supplied before higher forum is not verbatim same, it cannot sustain the validity of reopening of assessment under section 147 of the Income Tax Act.
The controversy in the present appeal relates to inclusion of an entity named E4e Healthcare Business Services Private Limited, as a comparable entity for benchmarking the international transaction of provision of IT-enabled services.
ITAT Mumbai held that GST/service tax which is collected by the assessee from its customers and paid to the Government do not form part of the receipts for computation of income as per section 44BB of the Income Tax Act.
ITAT Mumbai found DRP’s rejection of objections unjustified, remitting the Dresser-Rand case back to the AO for proper adjudication on Transfer Pricing issues.
TPO proposed transfer pricing adjustments of INR 1,03,26,939/-. According to TPO, appellant had advance funds to its AE [i.e. Golden Harvest Middle East (FZC)] under the grab of share application money and there was inordinate delay in allotment of shares.
ITAT Ahmedabad held that the TP assessment carried out by the TPO proceeded on the basis of incorrect appreciation of nature of services availed by the assessee from its AE. Thus, issue of determination of ALP of transactions with AE restored back to TPO.
