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 : ITAT Mumbai held management support fees were not taxable as FTS under Article 12(4) of the India-Singapore DTAA as the ‘make av...
Income Tax : ITAT Mumbai quashed reassessment after finding no Section 143(2) notice and that the AO issued a final order disguised as a draft ...
Income Tax : ITAT held that goodwill arising on amalgamation qualifies as a depreciable intangible asset. It also deleted the TP adjustment on ...
Income Tax : ITAT Delhi held that documentary evidence established receipt of intra-group administrative support services and that the 5% marku...
Income Tax : ITAT excluded EDCIL, Just Dial, Info Edge and India Exposition Mart as transfer pricing comparables due to functional differences ...
ITAT Mumbai held management support fees were not taxable as FTS under Article 12(4) of the India-Singapore DTAA as the ‘make available’ condition was not satisfied.
ITAT Mumbai quashed reassessment after finding no Section 143(2) notice and that the AO issued a final order disguised as a draft under Section 144C.
ITAT held that goodwill arising on amalgamation qualifies as a depreciable intangible asset. It also deleted the TP adjustment on overdue AE receivables.
ITAT Delhi held that documentary evidence established receipt of intra-group administrative support services and that the 5% markup was at arm’s length. The transfer pricing adjustment was accordingly deleted.
ITAT excluded EDCIL, Just Dial, Info Edge and India Exposition Mart as transfer pricing comparables due to functional differences and restored one comparable for verification.
ITAT upheld taxation of IPS and CEV subsidies following the Section 2(24) amendment, while partly allowing the appeal on other issues.
ITAT deleted the Section 68 addition after holding that the assessee fully established the lender, source of funds and genuineness.
ITAT held the assessment time-barred as the AO failed to pass the final order within the mandatory timeline under Section 144C(13).
The High Court held that the assessment was time-barred as it was not completed within the mandatory period under Section 144C.
ITAT held that stamp duty paid for lease registration was deductible as revenue expenditure in the year it was incurred.
