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...
The ITAT Hyderabad held that the assessment orders were time-barred under Section 153 despite the DRP process. Both assessments were quashed after applying the limitation prescribed under the Act.
The Hyderabad ITAT restored the issue to the Assessing Officer to verify whether project support and business development costs qualify as Head Office expenditure under Section 44C. It held that the classification requires factual verification before deciding the allowable deduction.
Tribunal held that final assessment order was time-barred because it was passed after mandatory period prescribed under Section 144C(13). Assessment was set aside, making remaining transfer pricing issues academic.
The ITAT held that a transfer pricing order issued without authentication or a digital signature is invalid in law. Consequently, it quashed the ₹85 crore transfer pricing adjustment and allowed the assessee’s appeals.
The ITAT held that the royalty and FTS adjustment was excessive and directed the Assessing Officer to apply the 1.9% rate accepted by the CBDT under the Unilateral Advance Pricing Agreement. It treated the APA principles as having persuasive value for determining the arm’s length price.
The ITAT Delhi held that dumpers used in manufacturing and mining operations are part of plant and machinery and qualify for additional depreciation under Section 32(1)(iia). It ruled that actual use, and not merely road-going capability, determines eligibility.
The Mumbai ITAT held that interest received by an Indian branch from its overseas head office and branches is not taxable under the domestic law as it represents transactions with self. The Tribunal applied the principle of mutuality and dismissed the Revenue’s challenge.
ITAT Ahmedabad held that the tax authorities failed to consider evidence of an earlier agreement and prior payments before invoking Section 56(2)(x). The addition based on the stamp duty value was deleted.
ITAT Mumbai held that Compulsorily Convertible Debentures retain their character as debt until conversion into equity. It deleted the disallowance of interest under Sections 36 and 37 while remanding the transfer pricing benchmarking issue.
ITAT Mumbai held that Compulsorily Convertible Debentures could not be treated as equity merely to deny interest deductions. The Tribunal deleted the ₹76.45 crore transfer pricing adjustment arising from such recharacterization.
