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...
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’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.
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.
Telangana HC overturns CBDT’s refusal to reassess Satyam’s tax after fraud, citing genuine hardship and unlawful tax collection.
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 High Court dismisses Siva Industries’ appeal due to a 2139-day delay, citing lack of diligence and bonafide reasons. Key judicial precedents considered.
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.
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.
ITAT Rajkot held that addition on account of unexplained investment in purchase of immovable property u/s 69 of the Income Tax Act is liable to be deleted since assessee sufficiently proved that all the payments are made from wife’s NRI account.
ITAT Mumbai held that sale of Dangerous Goods Regulations manuals could not be characterised as ‘royalty’ within the meaning of Article 12(3) of the India-Canada tax treaty. Accordingly, addition towards sale of manuals is deleted.
