#Section 144C
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543 articlesIncome Tax

Income Tax
DRP Directions Binding Once Uploaded: AO’s Timeline U/s. 144C(13) Clarified
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Revision u/s. 263 wouldn’t survive as assessment order held non-est: ITAT Delhi
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Dissimilar Firms were excluded from selected comparables while doing TP analysis u/s 92
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No addition for NRI investment in mutual funds as the same was legitimate
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Functionally dissimilar entities not includible as comparable for benchmarking international transactions
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TNMM appropriate method for determining Arm’s Length Price of management fees
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Cost imposed as order issued u/s. 143(3) wrongly challenged assuming it as draft assessment order u/s. 144C
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Income Tax
Section 144C(13) Compliance Timelines Begin from DRP Directions Upload Date
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Benefit under Direct Tax Vivad Se Vishwas available for pending review proceeding
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Reassessment quashed as reasons supplied to assessee & to higher forum were not same
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Functionally dissimilar entity not includible as comparable: Delhi HC
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GST amount do not form part of receipts for computation of income u/s. 44BB: ITAT Mumbai
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TAT Mumbai Finds DRP’s Summary Rejection Unjustified
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