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...
Delhi High Court held that notice issued u/s. 148 and assessment order thereon is liable to be set aside as sanction of issuance of notice not granted by authority specified under section 151 of the Income Tax Act. Accordingly, appeal of asset allowed and demand set aside.
The fact that the AO had in fact did not claim any carry forward of loss in the next assessment year would not be destructive of the petitioner’s right to exercise its option in terms of Rule 9(1) of the DTVSV Rules. Hence, the present petition is allowed.
Mumbai ITAT rules in favor of Tata Chemicals, allowing deduction of ₹156 crore interest on loans for overseas investment, overturning PCIT’s revision.
ITAT Mumbai held that it is the duty imposed on the Assessing Officer to complete the rectification process within six months. Thus, by remanding the matter back to the file of Assessing Officer, it is directed to complete the rectification within one month.
ITAT Jaipur held that expenditure towards supply of food packets for employees which was subjected to GST shall not be considered as contract and hence provisions of section 194C shall not apply.
ITAT Bangalore held that disallowance of entire royalty payment by taking ALP at NIL not justified since there is no change in facts, circumstances or functions and hence principle of consistency should be applied.
ITAT Delhi held that incentives in the form of excise duty refund, sales tax remission, sales/ VAT input tax refund received under the Incentive Scheme are capital receipts and hence not chargeable to income tax. Accordingly, ground of the assessee allowed.
ITAT Hyderabad held that reopening of assessment under section 147 of the Income Tax Act on the basis of invalid reasons recorded by AO cannot be sustained in law. Accordingly, notice issued u/s. 148 and final assessment order is quashed.
Delhi High Court held that since AY 2012-13 falls beyond the block of ten years that are required to be reckoned from the end of the AY 2022-23 assuming jurisdiction u/s. 153C in respect of AY 2012-13 is invalid. Accordingly, appeal of revenue dismissed.
ITAT Ahmedabad held that revisionary order passed under section 263 of the Income Tax Act in the name of non-existent entity (amalgamated company) is liable to be quashed. Accordingly, the appeal of the assessee is allowed.
