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#Section 144C

Every article filed under the “Section 144C” tag — analysis, news and updates.

543 articles
Income TaxITAT Allows BAPA Margin for Non-US AE Transactions Due to Identical FAR Profile
Income Tax

ITAT Allows BAPA Margin for Non-US AE Transactions Due to Identical FAR Profile

CA Sandeep Kanoi5 months ago
Income TaxITAT Orders Exclusion of Comparable as DRP Had Already Held It Functionally Different
Income Tax

ITAT Orders Exclusion of Comparable as DRP Had Already Held It Functionally Different

CA Sandeep Kanoi5 months ago
Income TaxAdvertisement Expenses Cannot Trigger TP Adjustment Without AE Arrangement
Income Tax

Advertisement Expenses Cannot Trigger TP Adjustment Without AE Arrangement

CA Sandeep Kanoi5 months ago
Income TaxSection 69C Addition Deleted as Customs Assessable Value Is Not Proof of Unexplained Expenditure
Income Tax

Section 69C Addition Deleted as Customs Assessable Value Is Not Proof of Unexplained Expenditure

CA Ajay Kumar Agrawal5 months ago
Income TaxITAT Quashes Assessment as DRP Order Upload Date Determined Limitation Period
Income Tax

ITAT Quashes Assessment as DRP Order Upload Date Determined Limitation Period

CA Sandeep Kanoi5 months ago
Income TaxChannel owners cannot be taken as comparables for distributors for transfer pricing purpose
Income Tax

Channel owners cannot be taken as comparables for distributors for transfer pricing purpose

POONAM GANDHI5 months ago
Income TaxPass-Through Costs Excluded From Transfer Pricing PLI as No Value Addition Was Performed: ITAT Mumbai
Income Tax

Pass-Through Costs Excluded From Transfer Pricing PLI as No Value Addition Was Performed: ITAT Mumbai

CA Sandeep Kanoi5 months ago
Income TaxTP Segment Split Rejected as Trading & After-Sales Services Are Inextricably Linked; TNMM at Entity Level Upheld: ITAT Delhi
Income Tax

TP Segment Split Rejected as Trading & After-Sales Services Are Inextricably Linked; TNMM at Entity Level Upheld: ITAT Delhi

CA Sandeep Kanoi5 months ago
Income TaxBombay HC Quashes TP Assessment for Missing 30-Day DRP Deadline
Income Tax

Bombay HC Quashes TP Assessment for Missing 30-Day DRP Deadline

UBR Legal Advocates5 months ago
Income TaxFinal Tax Order Set Aside Due to Failure to Issue Draft Assessment in International Transaction Case
Income Tax

Final Tax Order Set Aside Due to Failure to Issue Draft Assessment in International Transaction Case

CA Sandeep Kanoi5 months ago
Income TaxAPA with CBDT Binding; TPO Must Align ALP with APA Terms, Not Override: ITAT Kolkata
Income Tax

APA with CBDT Binding; TPO Must Align ALP with APA Terms, Not Override: ITAT Kolkata

CA Sandeep Kanoi5 months ago
Income TaxTransfer of passive infrastructure assets to Vodafone Infrastructure was a ‘Gift’ eligible for sec 47(iii) exemption
Income Tax

Transfer of passive infrastructure assets to Vodafone Infrastructure was a ‘Gift’ eligible for sec 47(iii) exemption

RATHI6 months ago
Income TaxTP Adjustment Restricted to AE Transactions Upheld – ITAT Bangalore Dismisses Revenue Appeal
Income Tax

TP Adjustment Restricted to AE Transactions Upheld – ITAT Bangalore Dismisses Revenue Appeal

CA Vijayakumar Shetty6 months ago
Income TaxOnline Platform Income Not Taxable as FTS Due to Failure of ‘Make Available’ Test: Delhi HC
Income Tax

Online Platform Income Not Taxable as FTS Due to Failure of ‘Make Available’ Test: Delhi HC

CA Sandeep Kanoi6 months ago