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...
Delhi High Court rules AO can’t deviate from Transfer Pricing Officer’s determined Arm’s Length Price (ALP) in international transactions, upholding assessee’s writ petition.
Read about the Madras High Court’s decision to quash an Income Tax assessment order issued while objections were pending before the Dispute Resolution Panel.
ITAT Delhi held that AO is bound to follow the directions of DRP. Accordingly, final assessment order passed by AO without implementing direction of DRP makes the assessment order void-ab-initio.
Delhi High Court rules investment in shares as capital account transaction, not income, in AL Amin Investments Limited Vs ACIT case. Analysis & judgment here.
Discover the ITAT Delhi ruling on taxing income from providing business support services to Indian group entities. Analysis of Solvay Asia vs. DCIT case under India-Thailand DTAA.
ITAT Mumbai held that the payment made towards interconnect usage charges to foreign telecom operators does not accrue or arise in India and in the absence of any permanent establishment in India could not be brought to tax in India under Article 7 of DTAA.
ITAT Kolkata held that for determining fair and true profit for the purpose of application of Transactional Net Margin Method (TNMM), it is appropriate that the effect of depreciation must be excluded.
ITAT Kolkata held that TPO should follow the direction of Hon’ble Dispute Resolution Panel (DRP). Accordingly, matter to the file of ld. TPO/AO for further calculation of TP adjustment by considering the direction of the Hon’ble DRP.
ITAT Delhi held that there is no provision regarding establishment of virtual service PE under India-Singapore DTAA and hence physical rendition of service in India is required under India-Singapore DTAA as per present service PE.
ITAT Kolkata held that foreign Associated Enterprises are least complex entities and accordingly can be treated as tested parties for comparability analysis of international transaction.
