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Section 144C

Latest Articles


Taxpayers Concerned as Assessment Orders Deviate from Orders Giving Effect

Income Tax : Taxpayers face challenges when assessment orders don’t reflect DRP directions. Misalignments lead to disputes, rectification iss...

October 4, 2024 2382 Views 0 comment Print

Eyes on Apex Court: Legal Community Awaits Supreme Court’s Verdict on Roca Bathroom Case

Income Tax : The legal community awaits the Supreme Court decision on the Roca Bathroom case, addressing timelines for transfer pricing assessm...

September 5, 2024 9150 Views 0 comment Print

Section 44C of Income Tax Act, 1961 Deduction of head office expenditure in case of Non-residents

Income Tax : Discover how Section 44C of the Income Tax Act, 1961, governs the deduction of head office expenses for non-resident businesses in...

July 19, 2024 3507 Views 0 comment Print


Latest Judiciary


Assuming jurisdiction u/s. 153C beyond block of ten years not tenable-in-law: Delhi HC

Income Tax : 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 t...

May 6, 2025 45 Views 0 comment Print

Revision order u/s. 263 passed in name of non-existent entity cannot be sustained: ITAT Ahmedabad

Income Tax : ITAT Ahmedabad held that revisionary order passed under section 263 of the Income Tax Act in the name of non-existent entity (amal...

May 6, 2025 42 Views 0 comment Print

ITAT Quashes Assessment Order Passed Without Complying Section 144C Provisions

Income Tax : ITAT Delhi quashes final assessment order passed without a mandatory draft order under Section 144C(1), deeming it void from the b...

May 5, 2025 249 Views 0 comment Print

Tax Loss Cannot Be Reduced by Unserved Section 143(1) Intimation: ITAT Ahmedabad

Income Tax : ITAT Ahmedabad rules that a GST intimation under section 143(1) is invalid if not served within the prescribed time limits to the ...

May 5, 2025 1347 Views 0 comment Print

Intra-Group Services Not Taxable in India as They Fall Outside FTS Scope: ITAT Delhi

Income Tax : ITAT Delhi held that services rendered under Intra Group Service Agreement do not make available technical knowledge and hence wou...

April 29, 2025 210 Views 0 comment Print


ITAT Delhi directed TPO to accept Advance Pricing Agreement parameters for royalty adjustment

April 9, 2025 108 Views 0 comment Print

ITAT Delhi held that Transfer Pricing Adjustment in respect of transaction of payment of royalty is set aside and Transfer Pricing Officer [TPO] is directed to accept the parameters of determination of compensation as accepted in Advance Pricing Agreement [APA].

Section 151A: JAO Lacks Jurisdiction to Issue Section 148 Income Tax Notices

April 9, 2025 4164 Views 0 comment Print

Rajasthan High Court held that, in terms of section 151A of the Income Tax Act, Jurisdictional Assessing Officer [JAO] doesn’t have jurisdiction to issue notices under section 148 of the Income Tax Act. Accordingly, notices u/s. 148 are liable to be quashed.

Quashing of Assessment order on non-compliance of sec 144C and barred by the period of Limitation

March 24, 2025 360 Views 0 comment Print

It was a case where the statutory procedure mandated in section 144C had been attempted to be by passed by merely mentioning the name of the assessee as the amalgamated entity with its former name and the name of amalgamating company.

GAIL India Appeal Dismissed After Opting for Vivad Se Vishwas

March 19, 2025 183 Views 0 comment Print

GAIL India’s ITAT Delhi appeal for AY 2018-19 was dismissed after opting for the Vivad Se Vishwas Scheme. Learn about the proceedings and decision details.

Reopening beyond 4 years without new material facts not sustainable in law: Gujarat HC

March 15, 2025 813 Views 0 comment Print

Gujarat High Court held that in the absence of new material facts brought on record by the Revenue reopening of assessment beyond the period of 4 years is found to be not sustainable in the eye of law. Thus, appeal of revenue dismissed.

Satyam Case: Telangana HC Orders Exclusion of Fictitious Income

March 11, 2025 1035 Views 0 comment Print

Telangana HC overturns CBDT’s refusal to reassess Satyam’s tax after fraud, citing genuine hardship and unlawful tax collection.

ITAT Allows Section 80G Deduction for CSR Donations to PM Relief Fund

March 9, 2025 492 Views 0 comment Print

ITAT Chennai rules CSR donations to PM Relief Fund qualify for 80G deduction, overturning AO’s decision. Read key judicial precedents and tax law insights.

Madras HC Declines to condone 2139-Day Delay Caused by Negligence

February 28, 2025 321 Views 0 comment Print

Madras High Court dismisses Siva Industries’ appeal due to a 2139-day delay, citing lack of diligence and bonafide reasons. Key judicial precedents considered.

Relief to Bloomsbury Publishing in Transfer Pricing Case

February 17, 2025 162 Views 0 comment Print

It was held that transactions and FAR of assessee were similar to AY 2021-­22 and as per the records brought to our notice, there was no change in the activities carried out by assessee in the current assessment year and subsequent assessment years.

TP adjustment under MAP cannot be applied to other international transaction

February 15, 2025 225 Views 0 comment Print

The US Transactions were subject to the Mutual Agreement Procedure between the competent authorities of US and India under Article 27 of the India-US Double Taxation Avoidance Agreement.

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