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...
Karnataka High Court held that re-adjustment of ALP without passing a Draft Assessment Order as required under section 144C of the Income Tax Act is not tenable in law. Accordingly, order passed thereon is void ab initio.
The ITAT granted Lowe’s India partial relief, allowing an 80G deduction for CSR donations while correcting MAT profit and other disallowances. The transfer pricing issue was remanded for a fresh review.
The ITAT has declared an assessment against SoftwareONE India Pvt. Ltd. void, ruling that an assessment framed in the name of a non-existent, merged entity is invalid, citing a Supreme Court precedent.
ITAT Mumbai held that depreciation on the business/commercial rights arising from the manufacturing contracts, supply contracts and maintenance contracts as claimed by the assessee is allowable. Accordingly, appeal allowed.
Revenue argued that since assessee was an “eligible assessee” under section 144C(15), AO rightly passed the order and the final order was valid within the time limit of section 153(4). On appeal.
ITAT Delhi held that the benefit of working capital adjustment while computing the ALP has also not been borne in mind hence matter restored to the file of TPO/ AO for fresh determination in accordance with law.
In the present cases, the respondents in the first batch of cases being non-resident assessees engaged in the business of exploration in terms of Section 44BB of the Income Tax Act, 1961, are eligible assessees within the meaning of Section 144C.
Delhi High Court sets aside reassessment order against Salesforce.Com Singapore, citing lack of jurisdiction and established judicial precedents on FTS.
ITAT Delhi rules that domain registration and web hosting fees are not taxable as royalty under India-UAE DTAA, citing key judicial precedents.
Addition made by AO in the hands of the trust was not justified as income from investments was taxable in the settlor’s hands and exempt under the India-UAE Double Taxation Avoidance Agreement (DTAA).
