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...
ITAT Delhi held that advertisement and distribution revenue earned by Discovery Asia Inc. is taxable as per Mutual Agreement Resolution (MAP) as decided by competent authority of India & USA. Accordingly, appeal allowed partially.
ITAT Bangalore held that merely because the assessee has failed to prove any benefit from services received the disallowance of transfer pricing cannot be made. Accordingly, one more opportunity granted to assessee to prove the case.
ITAT Ahmedabad remands case on unexplained investments of ₹18.19L in land & shares. Tribunal directs re-examination by AO after Assessee presents evidence.
Telangana HC examines Rapiscan Systems’ challenge on Income Tax assessment delays and statutory compliance in the 2018-19 and 2019-20 fiscal years.
ITAT Delhi held that revisionary proceedings under section 263 of the Income Tax Act would not survive since the assessment order is held to be non-est. Thus, appeal dismissed as having become infructuous.
The court held that the other three companies were also carrying out large-scale projects compared to assessee, making them unsuitable for comparison or setting industry standards.
AO had made the addition with the observation that no response was received from assessee. Based on that, he proceeded to complete the assessment u/s 144 based on the information available on his record.
The assessee had adopted Transactional Net Margin Method (TNMM) as the most appropriate method and Operating Profit/ Operating Cost [OP/OC] as the Profit Level Indicator for benchmarking the international transactions.
ITAT Ahmedabad held that that the activities / services do not qualify as stewardship / shareholder activity. Further, assessee correctly determined Arm’s Length Price in respect of management fees by using Transaction Net Margin Method i.e. TNMM.
Delhi High Court held that order issued u/s. 143(3) of the Income Tax Act wrongly challenged on the assumption that it is draft assessment order u/s. 144C is untenable in law. Accordingly, cost of ₹1,00,000/- imposed on petitioner.
