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 : ITAT Mumbai quashed reassessment after finding no Section 143(2) notice and that the AO issued a final order disguised as a draft ...
Income Tax : ITAT held that goodwill arising on amalgamation qualifies as a depreciable intangible asset. It also deleted the TP adjustment on ...
Income Tax : ITAT Delhi held that documentary evidence established receipt of intra-group administrative support services and that the 5% marku...
Income Tax : ITAT excluded EDCIL, Just Dial, Info Edge and India Exposition Mart as transfer pricing comparables due to functional differences ...
Income Tax : ITAT upheld taxation of IPS and CEV subsidies following the Section 2(24) amendment, while partly allowing the appeal on other iss...
ITAT Rajkot held that addition on account of unexplained investment in purchase of immovable property u/s 69 of the Income Tax Act is liable to be deleted since assessee sufficiently proved that all the payments are made from wife’s NRI account.
ITAT Mumbai held that sale of Dangerous Goods Regulations manuals could not be characterised as ‘royalty’ within the meaning of Article 12(3) of the India-Canada tax treaty. Accordingly, addition towards sale of manuals is deleted.
ITAT Delhi held that advertisement and distribution revenue earned by Discovery Asia Inc. is taxable as per Mutual Agreement Resolution (MAP) as decided by competent authority of India & USA. Accordingly, appeal allowed partially.
ITAT Bangalore held that merely because the assessee has failed to prove any benefit from services received the disallowance of transfer pricing cannot be made. Accordingly, one more opportunity granted to assessee to prove the case.
ITAT Ahmedabad remands case on unexplained investments of ₹18.19L in land & shares. Tribunal directs re-examination by AO after Assessee presents evidence.
Telangana HC examines Rapiscan Systems’ challenge on Income Tax assessment delays and statutory compliance in the 2018-19 and 2019-20 fiscal years.
ITAT Delhi held that revisionary proceedings under section 263 of the Income Tax Act would not survive since the assessment order is held to be non-est. Thus, appeal dismissed as having become infructuous.
The court held that the other three companies were also carrying out large-scale projects compared to assessee, making them unsuitable for comparison or setting industry standards.
AO had made the addition with the observation that no response was received from assessee. Based on that, he proceeded to complete the assessment u/s 144 based on the information available on his record.
The assessee had adopted Transactional Net Margin Method (TNMM) as the most appropriate method and Operating Profit/ Operating Cost [OP/OC] as the Profit Level Indicator for benchmarking the international transactions.
