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Section 144C

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Retrospective Amendments under Budget 2026 – Rectification, Revision, Reassessment Options before Tax Authorities

Income Tax : Budget 2026 introduces sweeping retrospective amendments affecting limitation, reassessment jurisdiction, DIN validity, and TPO ti...

February 26, 2026 6219 Views 1 comment Print

Special vs General: Time Limit Conflict between Section 144C(13) and Section 153 of Income Tax Act, 1961

Income Tax : Courts are divided on whether the DRP-specific deadline under Section 144C(13) overrides the general assessment time bar in Sectio...

December 16, 2025 2865 Views 0 comment Print

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 2958 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 17271 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 7197 Views 0 comment Print


Latest News


Income from Vessel Operations Taxable Under India-Norway DTAA: ITAT Delhi

Income Tax : Delhi ITAT allows Sanco Holding, a Norwegian company, to compute income from bareboat charter of seismic vessels under Article 21(...

October 17, 2025 807 Views 0 comment Print


Latest Judiciary


Remote access to customer systems for maintenance not create a PE in India: ITAT Delhi

Income Tax : The ITAT observed that mere remote access to customer-owned systems does not satisfy the disposal and permanence tests required fo...

May 21, 2026 99 Views 0 comment Print

ITAT Deletes Software Cost Mark-Up Addition Holding Pure Reimbursement Is Not Profit-Making Service

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-...

May 16, 2026 147 Views 0 comment Print

Transfer Pricing Addition Sent Back as DRP Failed to Properly Examine Functional Comparability

Income Tax : Tribunal found the DRP’s order cryptic and lacking proper analysis on similarity of business activities between the assessee and...

May 15, 2026 111 Views 0 comment Print

ITAT Allows BAPA Margin for Non-US AE Transactions Due to Identical FAR Profile

Income Tax : The Tribunal ruled that margins agreed under a Bilateral Advance Pricing Agreement may be used for non-covered AEs when transactio...

May 15, 2026 135 Views 0 comment Print

ITAT Orders Exclusion of Comparable as DRP Had Already Held It Functionally Different

Income Tax : Delhi ITAT directed exclusion of a comparable company engaged in video conferencing solutions after noting that the DRP had alread...

May 14, 2026 423 Views 0 comment Print


ITAT Quashes Assessment Order Passed Without Complying Section 144C Provisions

May 5, 2025 1113 Views 0 comment Print

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

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

May 5, 2025 1800 Views 0 comment Print

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

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

April 29, 2025 846 Views 0 comment Print

ITAT Delhi held that services rendered under Intra Group Service Agreement do not make available technical knowledge and hence would not fall within the definition of FTS as provided under Article 13(4) of India UK DTAA and hence not taxable in India.

Orders to Non-Existent Entities Void; Draft Assessment Order must for Section 144C

April 22, 2025 1599 Views 0 comment Print

ITAT Chennai rules on assessment orders issued to a non-existent entity after a merger. Learn about the legal implications and the impact on tax proceedings.

GST not includible in Gross Receipts for Income Computation U/S 44BB: ITAT Mumbai

April 21, 2025 1728 Views 0 comment Print

ITAT Mumbai held that GST would not form part of gross receipts for the purposes of computing presumptive income under Section 44BB of the Income Tax Act. Accordingly, appeal of the assessee allowed.

Reassessment proceeding u/s. 148 quashed as based on change of opinion

April 17, 2025 891 Views 0 comment Print

The petitioner filed its return of income u/s 139(1) of the Act on 24 November 2014 which was subsequently revised on two occasions namely on 17 March 2016 and 25 March 2016 which was further modified on 29 November 2016.

Provisioning for Asset Reconstruction Cost justified as AS 29 prescriptions qualified

April 10, 2025 378 Views 0 comment Print

Delhi High Court held that the provisioning for Asset Reconstruction Cost qualified the prescriptions of AS 29 and the assessee was thus justified in accounting for the same. Thus, that question is answered in favour of assessee.

No jurisdictional error if Faceless Assessment Procedure prescribed followed: Patna HC

April 10, 2025 2364 Views 0 comment Print

Patna High Court held that Faceless Assessment Procedure as prescribed under section 144B of the Income Tax Act is duly followed and in course of faceless assessment at every stage approval from competent authorities have been obtained.

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

April 9, 2025 582 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 7365 Views 1 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.

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