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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 198 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 123 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


Assuming jurisdiction u/s. 153C beyond block of ten years not tenable-in-law: Delhi HC

May 6, 2025 804 Views 0 comment Print

Delhi High Court held that since AY 2012-13 falls beyond the block of ten years that are required to be reckoned from the end of the AY 2022-23 assuming jurisdiction u/s. 153C in respect of AY 2012-13 is invalid. Accordingly, appeal of revenue dismissed.

Revision order u/s. 263 passed in name of non-existent entity cannot be sustained: ITAT Ahmedabad

May 6, 2025 444 Views 0 comment Print

ITAT Ahmedabad held that revisionary order passed under section 263 of the Income Tax Act in the name of non-existent entity (amalgamated company) is liable to be quashed. Accordingly, the appeal of the assessee is allowed.

ITAT Quashes Assessment Order Passed Without Complying Section 144C Provisions

May 5, 2025 1209 Views 0 comment Print

ITAT Delhi quashes final assessment order passed without a mandatory draft order under Section 144C(1), deeming it void from the beginning.

Tax Loss Cannot Be Reduced by Unserved Section 143(1) Intimation: ITAT Ahmedabad

May 5, 2025 1836 Views 0 comment Print

ITAT Ahmedabad rules that a GST intimation under section 143(1) is invalid if not served within the prescribed time limits to the assessee.

Intra-Group Services Not Taxable in India as They Fall Outside FTS Scope: ITAT Delhi

April 29, 2025 951 Views 0 comment Print

ITAT Delhi held that services rendered under Intra Group Service Agreement do not make available technical knowledge and hence would not fall within the definition of FTS as provided under Article 13(4) of India UK DTAA and hence not taxable in India.

Orders to Non-Existent Entities Void; Draft Assessment Order must for Section 144C

April 22, 2025 1689 Views 0 comment Print

ITAT Chennai rules on assessment orders issued to a non-existent entity after a merger. Learn about the legal implications and the impact on tax proceedings.

GST not includible in Gross Receipts for Income Computation U/S 44BB: ITAT Mumbai

April 21, 2025 1800 Views 0 comment Print

ITAT Mumbai held that GST would not form part of gross receipts for the purposes of computing presumptive income under Section 44BB of the Income Tax Act. Accordingly, appeal of the assessee allowed.

Reassessment proceeding u/s. 148 quashed as based on change of opinion

April 17, 2025 945 Views 0 comment Print

The petitioner filed its return of income u/s 139(1) of the Act on 24 November 2014 which was subsequently revised on two occasions namely on 17 March 2016 and 25 March 2016 which was further modified on 29 November 2016.

Provisioning for Asset Reconstruction Cost justified as AS 29 prescriptions qualified

April 10, 2025 414 Views 0 comment Print

Delhi High Court held that the provisioning for Asset Reconstruction Cost qualified the prescriptions of AS 29 and the assessee was thus justified in accounting for the same. Thus, that question is answered in favour of assessee.

No jurisdictional error if Faceless Assessment Procedure prescribed followed: Patna HC

April 10, 2025 2436 Views 0 comment Print

Patna High Court held that Faceless Assessment Procedure as prescribed under section 144B of the Income Tax Act is duly followed and in course of faceless assessment at every stage approval from competent authorities have been obtained.

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