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...
ITAT Delhi rules that domain registration and web hosting fees are not taxable as royalty under India-UAE DTAA, citing key judicial precedents.
Addition made by AO in the hands of the trust was not justified as income from investments was taxable in the settlor’s hands and exempt under the India-UAE Double Taxation Avoidance Agreement (DTAA).
Supreme Court held that Hyatt International has a fixed place Permanent Establishment in India within the meaning of Article 5(1) of the DTAA, and hence income received under Strategic Oversight Services Agreement [SOSA] attributable to such PE and is taxable in India.
The Kerala High Court has stayed recovery proceedings for one month, allowing petitioners to shift their income tax appeals to the Tribunal under Section 253(1)(d).
Penalty under section 271(1)(c) was not to be levied as Explanation 7 to section 271(1)(c), which specifically governs penalty in transfer pricing cases, was neither invoked during the initiation nor discussed while levying the penalty and neither TPO nor CIT(A) ever held that the ALP was computed outside the statutory provisions, or that the study report lacked diligence or was not prepared in good faith.
Delhi ITAT voids BBC World Service India’s 2017-18 tax assessment, ruling the final order was issued beyond the statutory time limit.
Bombay High Court sets aside Sulzer Pumps’ assessment order, citing pending DRP reference and procedural requirements under Section 144C of the Income Tax Act.
Madras High Court rules in favor of Enfinity Solar, quashing an assessment order due to the tax authorities’ failure to issue a mandatory draft assessment order after remand.
ITAT Delhi held that Bright Line Test doesn’t have statutory mandate and cannot be applied for determining Arm’s Length Price [ALP] of Advertisement, Marketing and Promotion [AMP] expense. Accordingly, appeal allowed to that extent.
Higher profit per se cannot lead to the conclusion that there is arrangement between the parties. The concept of PLI cannot per se be applied to hold that assessee has earned higher profit
