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...
Supreme Court held that Hyatt International has a fixed place Permanent Establishment in India within the meaning of Article 5(1) of the DTAA, and hence income received under Strategic Oversight Services Agreement [SOSA] attributable to such PE and is taxable in India.
The Kerala High Court has stayed recovery proceedings for one month, allowing petitioners to shift their income tax appeals to the Tribunal under Section 253(1)(d).
Penalty under section 271(1)(c) was not to be levied as Explanation 7 to section 271(1)(c), which specifically governs penalty in transfer pricing cases, was neither invoked during the initiation nor discussed while levying the penalty and neither TPO nor CIT(A) ever held that the ALP was computed outside the statutory provisions, or that the study report lacked diligence or was not prepared in good faith.
Delhi ITAT voids BBC World Service India’s 2017-18 tax assessment, ruling the final order was issued beyond the statutory time limit.
Bombay High Court sets aside Sulzer Pumps’ assessment order, citing pending DRP reference and procedural requirements under Section 144C of the Income Tax Act.
Madras High Court rules in favor of Enfinity Solar, quashing an assessment order due to the tax authorities’ failure to issue a mandatory draft assessment order after remand.
ITAT Delhi held that Bright Line Test doesn’t have statutory mandate and cannot be applied for determining Arm’s Length Price [ALP] of Advertisement, Marketing and Promotion [AMP] expense. Accordingly, appeal allowed to that extent.
Higher profit per se cannot lead to the conclusion that there is arrangement between the parties. The concept of PLI cannot per se be applied to hold that assessee has earned higher profit
ITAT Bangalore held that expansion of scope of limited scrutiny without obtaining required prior approval as directed under CBDT Order No. F.No.225/402/2018/ITA.II dated 28.11.2018 is bad-in-law and hence order of AO is liable to be quashed.
ITAT Delhi rules customer contracts, assembled workforce are intangible assets, allowing Genpact’s depreciation claim and affirming cost allocation.
