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 : ITAT Mumbai quashed reassessment after finding no Section 143(2) notice and that the AO issued a final order disguised as a draft ...
Income Tax : ITAT held that goodwill arising on amalgamation qualifies as a depreciable intangible asset. It also deleted the TP adjustment on ...
Income Tax : ITAT Delhi held that documentary evidence established receipt of intra-group administrative support services and that the 5% marku...
Income Tax : ITAT excluded EDCIL, Just Dial, Info Edge and India Exposition Mart as transfer pricing comparables due to functional differences ...
Income Tax : ITAT upheld taxation of IPS and CEV subsidies following the Section 2(24) amendment, while partly allowing the appeal on other iss...
The Tribunal held that additions not proposed in the original draft assessment order and unsupported by DRP directions could not be sustained. It reaffirmed that the statutory process under Section 144C must be followed before making prejudicial variations.
The ITAT held that a transfer pricing adjustment under Section 80-IA(10) cannot be sustained without proving the statutory conditions, including close connection, arranged business transactions, and more than ordinary profits. The Tribunal deleted the adjustment for lack of foundational evidence.
The ITAT Mumbai deleted a transfer pricing adjustment of ₹61.22 crore after finding the facts identical to an earlier assessment year. It held that a pending High Court appeal does not dilute the binding nature of an unreversed Tribunal decision.
ITAT ruled that determining the arm’s length price of management service fees at Nil without following a prescribed transfer pricing methodology was not sustainable. It upheld the CIT(A)’s order deleting both the management fee and manufacturing segment adjustments.
The ITAT Mumbai held that the final assessment order was passed beyond the mandatory timeline prescribed under Section 144C(13) after receipt of the DRP’s directions. It declared the assessment void ab initio and allowed the assessee’s appeal.
The ITAT Delhi held that the final assessment order was time-barred as it was passed beyond the mandatory period prescribed under Section 144C(13). The Tribunal ruled that internal departmental communications could not extend the statutory limitation and quashed the assessment.
The Delhi High Court held that the final assessment order was passed beyond the mandatory limitation period prescribed under Section 144C(13). It upheld the ITAT’s decision and dismissed the Revenue’s appeal.
The Tribunal distinguished between lack of enquiry and inadequate enquiry, holding that Section 263 cannot be invoked merely because the PCIT desired further verification. Since the AO had examined the evidence, the revisionary order was quashed.
The Tribunal ruled that although CSR expenditure is not allowable under Section 37, eligible donations made to recognised institutions can still qualify for deduction under Section 80G. The assessee’s claim was allowed for eligible donations.
ITAT Delhi held that an assessment framed after an approved merger in the name of the amalgamating company was without jurisdiction. The assessment order and DRP directions were set aside because the company had ceased to exist.
