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Section 144C

Latest Articles


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 2382 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 9273 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 3576 Views 0 comment Print


Latest Judiciary


Reopening u/s. 147 based on invalid reasons recorded by AO cannot be sustained: ITAT Hyderabad

Income Tax : ITAT Hyderabad held that reopening of assessment under section 147 of the Income Tax Act on the basis of invalid reasons recorded ...

May 7, 2025 318 Views 0 comment Print

Assuming jurisdiction u/s. 153C beyond block of ten years not tenable-in-law: Delhi HC

Income Tax : Delhi High Court held that since AY 2012-13 falls beyond the block of ten years that are required to be reckoned from the end of t...

May 6, 2025 108 Views 0 comment Print

Revision order u/s. 263 passed in name of non-existent entity cannot be sustained: ITAT Ahmedabad

Income Tax : ITAT Ahmedabad held that revisionary order passed under section 263 of the Income Tax Act in the name of non-existent entity (amal...

May 6, 2025 72 Views 0 comment Print

ITAT Quashes Assessment Order Passed Without Complying Section 144C Provisions

Income Tax : ITAT Delhi quashes final assessment order passed without a mandatory draft order under Section 144C(1), deeming it void from the b...

May 5, 2025 258 Views 0 comment Print

Tax Loss Cannot Be Reduced by Unserved Section 143(1) Intimation: ITAT Ahmedabad

Income Tax : ITAT Ahmedabad rules that a GST intimation under section 143(1) is invalid if not served within the prescribed time limits to the ...

May 5, 2025 1395 Views 0 comment Print


TP adjustment under MAP cannot be applied to other international transaction

February 15, 2025 228 Views 0 comment Print

The US Transactions were subject to the Mutual Agreement Procedure between the competent authorities of US and India under Article 27 of the India-US Double Taxation Avoidance Agreement.

Addition towards unexplained investment deleted as payment from NRI account proved

February 14, 2025 228 Views 0 comment Print

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.

Sale of Dangerous Goods Regulations manuals doesn’t tantamount to royalty

February 10, 2025 153 Views 0 comment Print

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.

Advertisement and distribution revenue of Discovery Asia INC. taxable as per MAP

February 7, 2025 177 Views 0 comment Print

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.

Transfer pricing disallowance as assessee failed to prove any benefit not justifiable: ITAT Bangalore

January 29, 2025 276 Views 0 comment Print

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 to AO

January 21, 2025 276 Views 0 comment Print

ITAT Ahmedabad remands case on unexplained investments of ₹18.19L in land & shares. Tribunal directs re-examination by AO after Assessee presents evidence.

DRP Directions Binding Once Uploaded: AO’s Timeline U/s. 144C(13) Clarified

January 13, 2025 1161 Views 0 comment Print

Telangana HC examines Rapiscan Systems’ challenge on Income Tax assessment delays and statutory compliance in the 2018-19 and 2019-20 fiscal years.

Revision u/s. 263 wouldn’t survive as assessment order held non-est: ITAT Delhi

January 10, 2025 711 Views 0 comment Print

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.

Dissimilar Firms were excluded from selected comparables while doing TP analysis u/s 92

January 1, 2025 165 Views 0 comment Print

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.

No addition for NRI investment in mutual funds as the same was legitimate

December 31, 2024 858 Views 0 comment Print

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.

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