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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 6498 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 3135 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 3027 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 17592 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 7485 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 888 Views 0 comment Print


Latest Judiciary


Section 143(2) Notice & Valid Draft Assessment Mandatory U/s 144C: ITAT Mumbai

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 ...

July 5, 2026 192 Views 0 comment Print

Amalgamation Goodwill Eligible for Depreciation; Notional Interest on AE Receivables Deleted: ITAT Delhi

Income Tax : ITAT held that goodwill arising on amalgamation qualifies as a depreciable intangible asset. It also deleted the TP adjustment on ...

July 4, 2026 117 Views 0 comment Print

Captive Service Provider Entitled to Risk Adjustment; Nil ALP for Proven Intra-Group Services Rejected: ITAT Delhi

Income Tax : ITAT Delhi held that documentary evidence established receipt of intra-group administrative support services and that the 5% marku...

July 4, 2026 117 Views 0 comment Print

ITAT Delhi Excludes TPO Comparables for Functional Dissimilarity

Income Tax : ITAT excluded EDCIL, Just Dial, Info Edge and India Exposition Mart as transfer pricing comparables due to functional differences ...

July 1, 2026 153 Views 0 comment Print

ITAT Deletes Brand Promotion TP Adjustment as Issue Was Already Settled in Earlier Years

Income Tax : ITAT upheld taxation of IPS and CEV subsidies following the Section 2(24) amendment, while partly allowing the appeal on other iss...

July 1, 2026 105 Views 0 comment Print


Expansion of scope of limited scrutiny not tenable as prior approval not obtained

June 25, 2025 1005 Views 0 comment Print

ITAT Bangalore held that expansion of scope of limited scrutiny without obtaining required prior approval as directed under CBDT Order No. F.No.225/402/2018/ITA.II dated 28.11.2018 is bad-in-law and hence order of AO is liable to be quashed.

Genpact Wins Tax Case: Intangible Assets Depreciable

June 21, 2025 1155 Views 0 comment Print

ITAT Delhi rules customer contracts, assembled workforce are intangible assets, allowing Genpact’s depreciation claim and affirming cost allocation.

Notice U/S 148 Invalid if issued Without Proper Section 151 Sanction: Delhi HC

June 20, 2025 2100 Views 0 comment Print

Delhi High Court held that notice issued u/s. 148 and assessment order thereon is liable to be set aside as sanction of issuance of notice not granted by authority specified under section 151 of the Income Tax Act. Accordingly, appeal of asset allowed and demand set aside.

Denial of DTVSV Benefits for Loss Carry Forward Based on Later Return Erroneous: Delhi HC

June 19, 2025 633 Views 0 comment Print

The fact that the AO had in fact did not claim any carry forward of loss in the next assessment year would not be destructive of the petitioner’s right to exercise its option in terms of Rule 9(1) of the DTVSV Rules. Hence, the present petition is allowed.

Tata Chemicals Secures ₹156 Cr Interest Deduction for Loan Used in Overseas Investment

June 17, 2025 867 Views 0 comment Print

Mumbai ITAT rules in favor of Tata Chemicals, allowing deduction of ₹156 crore interest on loans for overseas investment, overturning PCIT’s revision.

AO duty bound to complete Income Tax rectification process within six months

June 9, 2025 1383 Views 0 comment Print

ITAT Mumbai held that it is the duty imposed on the Assessing Officer to complete the rectification process within six months. Thus, by remanding the matter back to the file of Assessing Officer, it is directed to complete the rectification within one month.

Disallowance u/s. 40(a)(ia) set aside as TDS not deductible on supply of foods packets: ITAT Jaipur

May 30, 2025 1632 Views 0 comment Print

ITAT Jaipur held that expenditure towards supply of food packets for employees which was subjected to GST shall not be considered as contract and hence provisions of section 194C shall not apply.

TPO to determine ALP of royalty payment using TNMM method: ITAT Bangalore

May 17, 2025 957 Views 0 comment Print

ITAT Bangalore held that disallowance of entire royalty payment by taking ALP at NIL not justified since there is no change in facts, circumstances or functions and hence principle of consistency should be applied.

Incentives received under Incentive Scheme are capital receipts hence not taxable

May 13, 2025 1026 Views 0 comment Print

ITAT Delhi held that incentives in the form of excise duty refund, sales tax remission, sales/ VAT input tax refund received under the Incentive Scheme are capital receipts and hence not chargeable to income tax. Accordingly, ground of the assessee allowed.

Reopening u/s. 147 based on invalid reasons recorded by AO cannot be sustained: ITAT Hyderabad

May 7, 2025 1083 Views 0 comment Print

ITAT Hyderabad held that reopening of assessment under section 147 of the Income Tax Act on the basis of invalid reasons recorded by AO cannot be sustained in law. Accordingly, notice issued u/s. 148 and final assessment order is quashed.

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