#Section 144C
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508 articlesIncome Tax
Income Tax
Order not providing reasons on functionality of comparable for transfer pricing adjustment cannot sustain
Income Tax
Income Tax
Cost-to-cost reimbursements for IT support services not FIS under India-US DTAA
Income Tax
Income Tax
In Absence of PE, Software Licence Income Not Royalty Under India-USA DTAA: ITAT Delhi
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Helicopter Lease Held Operating, Not Financing: Article 8 Relief Granted Under India–Ireland DTAA
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Income Tax
Electronic Upload on ITBA = Legal Receipt: Physical Delivery Irrelevant, Says Delhi HC
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Reassessment Quashed for Addition Based on Retracted Search Statements & missing DIN
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Order Passed Beyond 3-Month Limit under Section 153(5) is Invalid: Karnataka HC
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“Egg-or-Chicken” Analogy Applied – ITAT Says Trading & Service Functions Can’t Be Split
Income Tax
Income Tax
ITAT Deletes Tax Additions Based on Uncorroborated Dumb Diaries & Retracted Statements
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Deputy Commissioner acting beyond directions given by DRP is contrary-in-law
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ITAT reduces Unexplained Deposit Addition from ₹2.28 Crore to ₹63,133
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ITAT Deletes ₹3.94 Crore TP Adjustment for Captive Software Provider
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TPO’s 20% Fantasy Margin Rejected – ITAT Removes Wrong Comparables Orders Fresh TP Computation
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Income Tax
