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...
Tribunal held that ₹15 crore received for withdrawing a civil suit was not consideration for transfer of a capital asset. It ruled that the assessee only gave up a right to sue, which is not taxable as capital gains.
The Hyderabad tribunal clarified that section 144C provisions are procedural and cannot extend the statutory limitation under section 153. The AO passed the final assessment order after the permissible period, leading to quashing. The ruling strengthens the principle that statutory deadlines are paramount in tax proceedings.
The Tribunal held that passing assessment orders after the statutory one-month period prescribed under Section 144C(13) is invalid. The assessee’s appeals were allowed, and both orders were set aside.
The Tribunal held that a reassessment notice issued beyond three years was invalid because approval was taken from the PCIT instead of the PCCIT. The ruling reiterates that the 2023 amendment to Section 151 cannot be applied retrospectively.
The ITAT held that excise-duty exemption for backward-area units is capital in nature since the incentive aims at industrial growth, not business profits. The ruling protects such incentives from tax under normal and AMT provisions.
ITAT Delhi held that DRP is a quasi-judicial authority and is required to issue directions on all the objections raised by assessee. Failure to adjudicate certain components results into violation of principles of natural justice. Accordingly, matter set aside to file of DRP.
The Tribunal found the Final Assessment Order invalid as it was issued before the 30-day objection period under Section 144C expired. This violated the assessee’s procedural rights. All transfer pricing adjustments and tax demands linked to the order were deleted, partly allowing the appeal.
The tribunal held that brought-forward losses and unabsorbed depreciation remain in the books until fully absorbed and must be allowed as reduction under Section 115JB. The ruling rejects the Revenue’s stand and upholds the CIT(A)’s deletion of the addition.
The ITAT found the AO’s valuation incorrect, emphasizing that FMV must be determined on the date of transfer, leading to the restoration of the long-term capital loss for the Assessee.
Tribunal held that civil, plumbing and electrical charges paid to builder formed part of the acquisition cost and allowed claim. It held that embedded fixtures qualify for deduction, while travel expenses unrelated to transfer do not.
