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...
In the case of Salesforce.com Singapore Pte Ltd. vs ACIT, ITAT Delhi ruled that receipts from CRM services aren’t taxable in India as royalty or FTS under the Income-tax Act or India-Singapore DTAA.
ITAT Delhi dismisses DCIT’s appeal against DLF Urban Pvt. Ltd. TPO failed to apply industry filter for ALP of interest, resulting in the deletion of Rs. 6.29 crores addition.
Assessee can’t be obstructed from availing of the benefits of the Direct Tax Vivad se Vishwas Act, 2020 (DTVSV Act) even where the time limit for an appeal had not expired as DTVSV Act aspired to finally free the tax arrears locked in the litigation combat for ages and ultimately ensures timely collection of tax.
The Delhi High Court ruled that once a TPO issues an order, the AO must pass an assessment order per Section 92CA(4) of the Income Tax Act.
Learn about the Chennai ITAT ruling in Conferencecall Services India Pvt. Ltd. vs. DCIT, where a final assessment made after one month of DRP directions was declared time-barred.
Understand the grounds of appeal in the case against the final assessment order under the Income Tax Act, 1961, for AY 2017-18, involving taxability of employee cost reimbursements and more.
ITAT Delhi rules non-resident’s salary for services rendered abroad not taxable in India, providing significant relief under India-Australia DTAA.
Learn about the case of Skybridge Solutions Private Limited vs. DCIT (ITAT Hyderabad) regarding the final assessment order passed under Section 144C without objection against the draft assessment order. Understand the implications and key takeaways from the judgment.
In a landmark ruling, ITAT Mumbai provides relief to Shell IT, asserting that payments for IT support aren’t considered FTS under India-Netherlands DTAA.
Read the full text of ITAT Mumbai’s order in the case of LANXESS India Pvt Ltd vs DCIT, upholding TNMM method over CUP for benchmarking export transactions under manufacturing segment.
