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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 6498 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 3135 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 3027 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 17592 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 7485 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 888 Views 0 comment Print


Latest Judiciary


Section 143(2) Notice & Valid Draft Assessment Mandatory U/s 144C: ITAT Mumbai

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 ...

July 5, 2026 192 Views 0 comment Print

Amalgamation Goodwill Eligible for Depreciation; Notional Interest on AE Receivables Deleted: ITAT Delhi

Income Tax : ITAT held that goodwill arising on amalgamation qualifies as a depreciable intangible asset. It also deleted the TP adjustment on ...

July 4, 2026 117 Views 0 comment Print

Captive Service Provider Entitled to Risk Adjustment; Nil ALP for Proven Intra-Group Services Rejected: ITAT Delhi

Income Tax : ITAT Delhi held that documentary evidence established receipt of intra-group administrative support services and that the 5% marku...

July 4, 2026 117 Views 0 comment Print

ITAT Delhi Excludes TPO Comparables for Functional Dissimilarity

Income Tax : ITAT excluded EDCIL, Just Dial, Info Edge and India Exposition Mart as transfer pricing comparables due to functional differences ...

July 1, 2026 153 Views 0 comment Print

ITAT Deletes Brand Promotion TP Adjustment as Issue Was Already Settled in Earlier Years

Income Tax : ITAT upheld taxation of IPS and CEV subsidies following the Section 2(24) amendment, while partly allowing the appeal on other iss...

July 1, 2026 99 Views 0 comment Print


Mistake apparent pertaining to carry forward and set off of unabsorbed depreciation and business losses could be revised by filing Form 3 under VSV scheme

October 18, 2024 1215 Views 0 comment Print

The failure of assessee to make the requisite disclosures in Schedule D would neither detract from the relief which had been accorded by AO nor change the factum of carry forward and set off as forming part of the assessment order.

Passing final assessment order beyond prescribed limit u/s. 144C bad-in-law: Delhi HC

October 16, 2024 792 Views 0 comment Print

The Revenue has filed the present appeal under Section 260A the Income Tax Act, 1961 impugning an order dated 05.01.2024 passed by the Income Tax Appellate Tribunal in ITA No.185/Del/2023 in respect of the assessment year 2013-14.

Taxpayers Concerned as Assessment Orders Deviate from Orders Giving Effect

October 4, 2024 3027 Views 0 comment Print

Taxpayers face challenges when assessment orders don’t reflect DRP directions. Misalignments lead to disputes, rectification issues, and relief from appellate authorities.

Salary for international assignment subjected to tax in UK is not taxable in India

October 3, 2024 1200 Views 0 comment Print

ITAT Chennai held that salary received for international assignment which is subjected to tax in UK could not be taxed in India. Accordingly, claim of the assessee allowed. The assessee being non-resident individual filed return of income declaring income of Rs.2295/- and claiming refund of Rs.10.08 Lacs.

Final assessment order set aside as passed before disposal of rectification application: Karnataka HC

October 1, 2024 636 Views 0 comment Print

Karnataka High Court held that since rectification application was filed before passing of final assessment order, DRP ought to have waited till disposal of rectification application. Thus, final assessment order liable to be set aside.

Cloud Subscription Fees Not Royalty under India-Ireland DTAA: ITAT Delhi

September 30, 2024 1155 Views 0 comment Print

ITAT Delhi rules that subscription fees from cloud services are not taxable as royalty under the India-Ireland DTAA. 

Damages is capital receipt but interest on damages is revenue receipt: ITAT Delhi

September 24, 2024 1302 Views 0 comment Print

ITAT Delhi held that damages are compensation received is a capital receipt, however, interest on damages is to be treated as revenue receipt hence the same is taxable.

Amount Received from US Broadcasting Company Not Taxable as “Royalty” Under India-US DTAA

September 24, 2024 930 Views 0 comment Print

Distribution revenue received by Turner Broadcasting System Asia Pacific, Inc. ( TBSAP ), a U.S.-based company, from its Indian affiliate was not taxable as “royalty” under the Income Tax Act, 1961, or the India-U.S.

Matter remanded as TP adjustment could not be at ‘NIL’ as determined by TPO

September 23, 2024 1014 Views 0 comment Print

Assessee claimed to have receiving services in the fields of technology, Services, Risk Information Management, Head quarter, Technology Services/back office support services/treasury/regional headquarter services etc.

Non-intimation to AO before removal of company’s name from ROC, assessment was valid even if passed in name of non-existent entity

September 23, 2024 1110 Views 0 comment Print

Alena Cyprus had also filed its return of income in India for the AY 2018-19 wherein LTCG of Rs. 80,86,75,225 arising from sale of shares to assessee were declared exemption claimed under Article 13 of the India-Cyprus DTAA.

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