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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


ITAT Delhi directed TPO to accept Advance Pricing Agreement parameters for royalty adjustment

April 9, 2025 681 Views 0 comment Print

ITAT Delhi held that Transfer Pricing Adjustment in respect of transaction of payment of royalty is set aside and Transfer Pricing Officer [TPO] is directed to accept the parameters of determination of compensation as accepted in Advance Pricing Agreement [APA].

Section 151A: JAO Lacks Jurisdiction to Issue Section 148 Income Tax Notices

April 9, 2025 7542 Views 1 comment Print

Rajasthan High Court held that, in terms of section 151A of the Income Tax Act, Jurisdictional Assessing Officer [JAO] doesn’t have jurisdiction to issue notices under section 148 of the Income Tax Act. Accordingly, notices u/s. 148 are liable to be quashed.

Quashing of Assessment order on non-compliance of sec 144C and barred by the period of Limitation

March 24, 2025 1116 Views 0 comment Print

It was a case where the statutory procedure mandated in section 144C had been attempted to be by passed by merely mentioning the name of the assessee as the amalgamated entity with its former name and the name of amalgamating company.

GAIL India Appeal Dismissed After Opting for Vivad Se Vishwas

March 19, 2025 468 Views 0 comment Print

GAIL India’s ITAT Delhi appeal for AY 2018-19 was dismissed after opting for the Vivad Se Vishwas Scheme. Learn about the proceedings and decision details.

Reopening beyond 4 years without new material facts not sustainable in law: Gujarat HC

March 15, 2025 1254 Views 0 comment Print

Gujarat High Court held that in the absence of new material facts brought on record by the Revenue reopening of assessment beyond the period of 4 years is found to be not sustainable in the eye of law. Thus, appeal of revenue dismissed.

Satyam Case: Telangana HC Orders Exclusion of Fictitious Income

March 11, 2025 1557 Views 0 comment Print

Telangana HC overturns CBDT’s refusal to reassess Satyam’s tax after fraud, citing genuine hardship and unlawful tax collection.

ITAT Allows Section 80G Deduction for CSR Donations to PM Relief Fund

March 9, 2025 1671 Views 0 comment Print

ITAT Chennai rules CSR donations to PM Relief Fund qualify for 80G deduction, overturning AO’s decision. Read key judicial precedents and tax law insights.

Madras HC Declines to condone 2139-Day Delay Caused by Negligence

February 28, 2025 963 Views 0 comment Print

Madras High Court dismisses Siva Industries’ appeal due to a 2139-day delay, citing lack of diligence and bonafide reasons. Key judicial precedents considered.

Relief to Bloomsbury Publishing in Transfer Pricing Case

February 17, 2025 525 Views 0 comment Print

It was held that transactions and FAR of assessee were similar to AY 2021-­22 and as per the records brought to our notice, there was no change in the activities carried out by assessee in the current assessment year and subsequent assessment years.

TP adjustment under MAP cannot be applied to other international transaction

February 15, 2025 774 Views 0 comment Print

The US Transactions were subject to the Mutual Agreement Procedure between the competent authorities of US and India under Article 27 of the India-US Double Taxation Avoidance Agreement.

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