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 restored Fiserv India’s appeal, citing CIT(A)’s failure to address adjournment requests. The case will be reconsidered for a fair hearing and review.
Delhi High Court held that passing of a draft assessment order as mandated under section 144C of the Income Tax Act is mandatory prior to passing of final assessment order. Accordingly, order liable to be set aside.
The legal community awaits the Supreme Court decision on the Roca Bathroom case, addressing timelines for transfer pricing assessments under Sections 153 and 144C.
ITAT Delhi rules Coursera’s income from Indian customers not taxable as Fees for Technical Services (FTS) under India-USA DTAA. A key decision for online platforms.
ITAT Delhi held that routine support services would not be taxable as Fees for Technical Services (FTS) in terms of the provisions of India-UK Double Taxation Avoidance Agreement (DTAA).
Amount received as reimbursements for expenses related to software subscription services should not be taxed as technical services income under Article 12 of the of the India-USA Double Taxation Avoidance Agreement ( DTAA ) or Section 9(1)(vii).
ITAT Hyderabad directed to exclude companies having turnover of more than or less than 10 times of the turnover of the assessee from the list of comparable. Accordingly, matter remanded back to the file of AO/ TPO.
Delhi High Court held that once the Tribunal had called upon the AO to examine the issue afresh, the said direction could not have been disregarded by reference to a Circular No. 549 dated 31 October 1989 issued by the CBDT.
ITAT Delhi held that long term capital gain on sale of shares in case of the assessee company, being resident of Mauritius, is not liable to be taxed in India.
Delhi High Court held that the receipts from Indian customers for services provided outside Indian Territory, in connection with use or right to use of process or equipment by the assessee company, cannot be taxed as royalty as per section 9(l)(vi) of the Income Tax Act.
