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 Ahmedabad held that benefit demonstrated in form of reduced interest rate on account of guarantee, thus, payment of guarantee fee justifiable. Accordingly, TP adjustment on account of the guarantee fee payment to AE deleted.
ITAT Chennai restored the matter back to the file of AO for re-adjudication as additional ground raised by the assessee in appeal were not taken up before lower authorities.
Discover how Section 44C of the Income Tax Act, 1961, governs the deduction of head office expenses for non-resident businesses in India.
Read the full text of the ITAT Delhi order on Cricket Australia vs. ACIT (International Taxation). Analysis includes why license fees from live cricket match transmissions held in Australia are not considered royalty under Indian tax laws.
Delhi ITAT rules in Ares Diversified Vs ACIT that rejection of belated objections by DRP does not extend the limitation for passing final assessment U/s 144(4).
Read about Bombay High Courts decision upholding ITAT’s order directing Vodafone India to deposit Rs.230 crores to stay income tax demands, analyzing the legal implications and challenges faced.
Read the full text of the Delhi ITAT order on Denso (Thailand) vs ACIT, discussing tax liability for technical services under India-Thailand DTAA, absence of FTS clause, and PE considerations.
ITAT emphasized that under the accrual system, provisions for outstanding expenses can indeed be recognized based on estimates and do not require exact certainty at the time of accrual. The fact that the statutory auditors had approved the financial statements without qualification further supported Culver Max’s position that these provisions represented ascertained liabilities within the framework of accrual-based accounting.
Delhi High Court judgment on GE Capital vs. DCIT, distinguishing under-reporting and misreporting as separate offenses, resulting in quashed penalty. Full text analysis.
Guarantee commission charges received by a foreign parent company from its Indian subsidiaries were taxable in India, not as interest but as “other income” under Article 23(3) of the DTAA.
