Income Tax : Budget 2026 introduces sweeping retrospective amendments affecting limitation, reassessment jurisdiction, DIN validity, and TPO ti...
Income Tax : Courts are divided on whether the DRP-specific deadline under Section 144C(13) overrides the general assessment time bar in Sectio...
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 : Delhi ITAT allows Sanco Holding, a Norwegian company, to compute income from bareboat charter of seismic vessels under Article 21(...
Income Tax : The ITAT observed that mere remote access to customer-owned systems does not satisfy the disposal and permanence tests required fo...
Income Tax : The ITAT Delhi ruled that reimbursement of software costs to foreign AEs on a cost-to-cost basis could not be treated as a profit-...
Income Tax : Tribunal found the DRP’s order cryptic and lacking proper analysis on similarity of business activities between the assessee and...
Income Tax : The Tribunal ruled that margins agreed under a Bilateral Advance Pricing Agreement may be used for non-covered AEs when transactio...
Income Tax : Delhi ITAT directed exclusion of a comparable company engaged in video conferencing solutions after noting that the DRP had alread...
The ITAT observed that mere remote access to customer-owned systems does not satisfy the disposal and permanence tests required for constituting a Fixed Place PE under the India-Canada DTAA.
The ITAT Delhi ruled that reimbursement of software costs to foreign AEs on a cost-to-cost basis could not be treated as a profit-generating intra-group service. The Tribunal deleted the transfer pricing adjustment after finding the benchmarking method adopted by the TPO unjustified.
Tribunal found the DRP’s order cryptic and lacking proper analysis on similarity of business activities between the assessee and selected comparables. Fresh examination was directed regarding comparability and ALP computation.
The Tribunal ruled that margins agreed under a Bilateral Advance Pricing Agreement may be used for non-covered AEs when transactions are functionally similar. The decision emphasized consistency and the lack of separate benchmarking by the TPO.
Delhi ITAT directed exclusion of a comparable company engaged in video conferencing solutions after noting that the DRP had already found it functionally incomparable to the assessee’s software distribution business.
The Delhi ITAT held that advertisement and marketing expenses could not be treated as an international transaction without evidence of an arrangement with the associated enterprise. The Tribunal deleted the transfer pricing adjustment and rejected the application of the Bright Line Test.
The Tribunal held that differences between customs assessable value and invoice value cannot automatically justify additions under Section 69C. The ruling clarifies that actual unexplained expenditure must first be proved by the Revenue.
The ITAT Delhi held that the upload date of DRP directions on the ITBA portal must be considered for computing limitation under Section 144C(13). Since the final assessment order was passed beyond the prescribed period, the assessment was quashed as time-barred.
ITAT Delhi held that companies owning and operating channels cannot be compared with distribution company for the purpose of transfer pricing. Accordingly, directs TPO to exclude such comparables for benchmarking distribution segment and determination of ALP.
ITAT Mumbai held that payments made to third-party vendors on a cost-to-cost basis, without any value addition by the assessee, should be treated as pass-through costs and excluded from PLI computation.
