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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 6219 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 2865 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 2958 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 17271 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 7197 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 807 Views 0 comment Print


Latest Judiciary


Remote access to customer systems for maintenance not create a PE in India: ITAT Delhi

Income Tax : The ITAT observed that mere remote access to customer-owned systems does not satisfy the disposal and permanence tests required fo...

May 21, 2026 99 Views 0 comment Print

ITAT Deletes Software Cost Mark-Up Addition Holding Pure Reimbursement Is Not Profit-Making Service

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-...

May 16, 2026 147 Views 0 comment Print

Transfer Pricing Addition Sent Back as DRP Failed to Properly Examine Functional Comparability

Income Tax : Tribunal found the DRP’s order cryptic and lacking proper analysis on similarity of business activities between the assessee and...

May 15, 2026 111 Views 0 comment Print

ITAT Allows BAPA Margin for Non-US AE Transactions Due to Identical FAR Profile

Income Tax : The Tribunal ruled that margins agreed under a Bilateral Advance Pricing Agreement may be used for non-covered AEs when transactio...

May 15, 2026 135 Views 0 comment Print

ITAT Orders Exclusion of Comparable as DRP Had Already Held It Functionally Different

Income Tax : Delhi ITAT directed exclusion of a comparable company engaged in video conferencing solutions after noting that the DRP had alread...

May 14, 2026 423 Views 0 comment Print


Section 44BB does not override provisions related to PE or DTAA benefits

May 9, 2024 741 Views 0 comment Print

Read the detailed analysis of Computer Modelling Group Ltd. vs. ACIT (ITAT Delhi) regarding interest leviable from the assessee for short payment of tax due to payer’s TDS default before FY 2012-2013.

Consider Volume Discount & Geographic Price Variation in TP Adjustment: ITAT Ahmedabad

May 8, 2024 801 Views 0 comment Print

Ahmedabad ITAT’s order in Atul Limited vs DCIT case discusses TP adjustments, volume discount, geography adjustments, and more. Detailed analysis provided.

Ahmedabad ITAT Clarifies Letter of Credit vs. Bank Guarantee in Transfer Pricing Dispute

May 8, 2024 1605 Views 0 comment Print

In a detailed analysis of Axis Bank Limited Vs ACIT case, Ahmedabad ITAT explains the difference between a Letter of Credit and Corporate Guarantee, resolving disallowance disputes.

Bullion Purchases: LBMA Rates vs. KITCO and Reuters for ALP

May 6, 2024 675 Views 0 comment Print

ITAT considered the justification provided by the assessee, which referenced KITCO and Reuters databases for determining transaction prices. However, the Transfer Pricing Officer (TPO) argued that the London Bullion Market Association (LBMA) should be the primary source for estimating bullion trading prices.

Post-filing Corrections to Form 35A cannot be treated as filed beyond time limit

May 5, 2024 1137 Views 0 comment Print

ITAT found that the original Form 35A was filed within the stipulated time and ruled that the correction made thereafter should not be considered late.

STCL Taxable at 15% Can be set-ff against STCG Taxable at 30%: ITAT Mumbai

May 5, 2024 1563 Views 0 comment Print

Explore the detailed analysis of JS Capital LLC Vs ACIT (ITAT Mumbai) regarding the offsetting of Short Term Capital Loss (STCL) against Short Term Capital Gain (STCG) under section 70(2) of the Income Tax Act.

ITAT allows deduction of interest paid on Perpetual Non-Convertible Debentures (PNCD)

April 21, 2024 1269 Views 0 comment Print

ITAT Mumbai grants relief to Tata Steel Limited, allowing deduction of interest paid on Perpetual Non-Convertible Debentures (PNCD) under section 36(1)(iii) of the Act. 

Stay on Income Tax Recovery can be granted if 20% Tax Already been paid: Kerala HC

April 19, 2024 1443 Views 1 comment Print

Kerala High Court’s judgment on applicability of CBDT Circular regarding deposition of assessed tax when appeal lies only before ITAT. Analysis and conclusion provided.

Final Assessment Order Invalid without Draft Section u/s 144C(1) Order: ITAT Mumbai

April 12, 2024 1950 Views 0 comment Print

ITAT Mumbai quashes assessment order in Welspun Global Brands Ltd Vs DCIT case. AO failed to follow Sec 144C(1) of Income Tax Act, rendering order invalid.

After initiation of resolution process appeal not maintainable if not filed by IRP

April 11, 2024 489 Views 0 comment Print

Since the appellant hadn’t filed the appeal through the Interim Resolution Professional as required under the resolution process, the ITAT deemed the appeal not maintainable and dismissed it.

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