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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 2385 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 9375 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 3585 Views 0 comment Print


Latest Judiciary


Reopening u/s. 147 based on invalid reasons recorded by AO cannot be sustained: ITAT Hyderabad

Income Tax : ITAT Hyderabad held that reopening of assessment under section 147 of the Income Tax Act on the basis of invalid reasons recorded ...

May 7, 2025 381 Views 0 comment Print

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 117 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 75 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 276 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 1413 Views 0 comment Print


Foreign Currency Convertible Bond expenses included as FCCB premium expense is allowable

June 13, 2023 624 Views 0 comment Print

ITAT Mumbai held that FCCB i.e. Foreign Currency Convertible Bond expenses included as part of FCCB premium expenses is allowable.

Addition towards disallowance u/s 14A to book profit computed u/s 115JB is unsustainable

June 6, 2023 309 Views 0 comment Print

ITAT Chennai held that additions made towards disallowance u/s. 14A r.w.r. 8D of the I.T. Rules, 1962 to book profit computed u/s. 115JB(2) of the Income Tax Act is unsustainable.

Disallowance u/s 14A untenable on mechanical application of rule 8D

June 5, 2023 1353 Views 0 comment Print

ITAT Mumbai held that disallowance u/s 14A untenable as AO has mechanically applied rule 8D without having recorded his satisfaction or examining the nature of investments whether they have yielded any exempt income or not.

Expenditure towards ESOP is allowable deduction u/s 37

May 24, 2023 1407 Views 0 comment Print

ITAT Bangalore held that expenditure towards Employees Stock Option Plan (ESOP) is allowable deduction u/s 37 of the Income Tax Act.

Assessment order passed on a non-existent company is null and void

May 24, 2023 1080 Views 0 comment Print

ITAT Ahmedabad held that draft assessment order u/s 143(3) read with section 144C of the Income Tax Act passed on a non-existent company is null and void.

Chapter X cannot be invoked for making TP adjustment in case of AMP expenses

May 23, 2023 795 Views 0 comment Print

ITAT Mumbai held that provisions of Chapter X cannot be invoked for making a TP adjustment in case of Advertisement, marketing and promotion (AMP) expenses.

Capitalized Expense shouldn’t be considered for computation of proportionate TP adjustment

May 22, 2023 690 Views 0 comment Print

ITAT Bangalore held that as professional and consultation charges & purchase of fixed assets are capitalized in the books of accounts, it should not be considered for computation of proportionate TP adjustment.

Interest on FCCDs is to be computed by applying LIBOR plus 200 points

May 17, 2023 1131 Views 0 comment Print

ITAT Hyderabad held that FCCDs are debt hence interest paid/ payable on FCCDs in to be computed by applying LIBOR plus 200 basis points.

Business profit not taxable in India in absence of any permanent establishment

May 3, 2023 1470 Views 0 comment Print

ITAT Delhi held that payment received in the nature of Business Profit cannot be brought to tax in India in absence of Permanent Establishment in India.

Writ not entertained as effective alternative remedy u/s 144C available

May 1, 2023 1059 Views 0 comment Print

Telangana High Court held that writ jurisdiction under Article 226 of the Constitution of India not invocable as adequate and effective alternative remedy under Section 144C of the Act by way of filing objections before the Dispute Resolution panel available to the petitioner.

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