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...
The Tribunal held that trading and service activities were inextricably linked and could not be segmented. It accepted entity-level TNMM, rendering TP adjustments unsustainable.
The issue was failure to pass a final assessment order after DRP directions within the statutory timeline. The Court held the assessment invalid and time-barred, quashing the proceedings.
The court examined whether a final assessment order could stand without issuing a draft order to an eligible assessee. It held that bypassing the mandatory draft assessment process invalidates the final order and renders it void.
The case examined whether transfer pricing adjustments could stand when an APA covered the relevant year. The Tribunal remanded the matter for reconsideration in line with the APA framework.
Transfer of passive infrastructure (PI) assets under a court-approved scheme of demerger without consideration qualified as a gift under Section 47(iii), thereby legitimizing the claim of depreciation on such assets.
ITAT Bangalore upholds restricting TP adjustment only to AE transactions, dismissing Revenues appeal. Confirms capacity, working capital adjustments and consistency in forex/provision treatment.
The case examined whether online learning services involve technical services. The Court ruled that the platform only facilitated access to content and did not provide technical services. The decision clarifies tax treatment of digital platforms.
The issue concerned failure to follow tribunal remand directions on comparables. The ruling held that such non-compliance caused procedural irregularity, leading to exclusion of certain comparables and recomputation of ALP.
The issue was addition of cash deposits during demonetisation as unexplained income. The Tribunal held that the assessee’s explanation supported by affidavit was credible, leading to deletion of the addition.
The Tribunal held that an assessment order passed in compliance with DRP directions cannot be revised under Section 263. It clarified that such orders are not erroneous as the Assessing Officer is bound by DRP’s binding instructions.
