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...
Where the Transfer Pricing Officer (TPO) accepted international transactions at arm’s length without proposing any variation under Section 92CA(3), assessee did not qualify as an “eligible assessee” under Section 144C(15)(b).
AO was bound to follow the CBDT circular 19/2019 (F. NO.225/95/2019-ITA.II], DATED 14-82019 and the omission/dereliction was anathema to the basic feature of our Constitution “Rule of Law”, so his impugned action of passing the assessment order without quoting the DIN was held to be arbitrary exercise of power and therefore, invalid.
Karnataka High Court held that re-adjustment of ALP without passing a Draft Assessment Order as required under section 144C of the Income Tax Act is not tenable in law. Accordingly, order passed thereon is void ab initio.
The ITAT granted Lowe’s India partial relief, allowing an 80G deduction for CSR donations while correcting MAT profit and other disallowances. The transfer pricing issue was remanded for a fresh review.
The ITAT has declared an assessment against SoftwareONE India Pvt. Ltd. void, ruling that an assessment framed in the name of a non-existent, merged entity is invalid, citing a Supreme Court precedent.
ITAT Mumbai held that depreciation on the business/commercial rights arising from the manufacturing contracts, supply contracts and maintenance contracts as claimed by the assessee is allowable. Accordingly, appeal allowed.
Revenue argued that since assessee was an “eligible assessee” under section 144C(15), AO rightly passed the order and the final order was valid within the time limit of section 153(4). On appeal.
ITAT Delhi held that the benefit of working capital adjustment while computing the ALP has also not been borne in mind hence matter restored to the file of TPO/ AO for fresh determination in accordance with law.
In the present cases, the respondents in the first batch of cases being non-resident assessees engaged in the business of exploration in terms of Section 44BB of the Income Tax Act, 1961, are eligible assessees within the meaning of Section 144C.
Delhi High Court sets aside reassessment order against Salesforce.Com Singapore, citing lack of jurisdiction and established judicial precedents on FTS.
