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...
Thereafter, the petitioner lodged objections on 10.03.2022. The impugned Draft Assessment Order was issued thereafter on 30.03.2022 u/s. 144C of the Act. Being aggrieved, the present writ is filed.
ITAT Mumbai held that when the reserve/provisions created in the year where the assessee has increased the book profit u/s. 115JB of the Act, the assessee is entitled to reduce the amount withdrawn from such reserve if the same is credited to the P & L account in that year.
ITAT Delhi restored Fiserv India’s appeal, citing CIT(A)’s failure to address adjournment requests. The case will be reconsidered for a fair hearing and review.
Delhi High Court held that passing of a draft assessment order as mandated under section 144C of the Income Tax Act is mandatory prior to passing of final assessment order. Accordingly, order liable to be set aside.
The legal community awaits the Supreme Court decision on the Roca Bathroom case, addressing timelines for transfer pricing assessments under Sections 153 and 144C.
ITAT Delhi rules Coursera’s income from Indian customers not taxable as Fees for Technical Services (FTS) under India-USA DTAA. A key decision for online platforms.
ITAT Delhi held that routine support services would not be taxable as Fees for Technical Services (FTS) in terms of the provisions of India-UK Double Taxation Avoidance Agreement (DTAA).
Amount received as reimbursements for expenses related to software subscription services should not be taxed as technical services income under Article 12 of the of the India-USA Double Taxation Avoidance Agreement ( DTAA ) or Section 9(1)(vii).
ITAT Hyderabad directed to exclude companies having turnover of more than or less than 10 times of the turnover of the assessee from the list of comparable. Accordingly, matter remanded back to the file of AO/ TPO.
Delhi High Court held that once the Tribunal had called upon the AO to examine the issue afresh, the said direction could not have been disregarded by reference to a Circular No. 549 dated 31 October 1989 issued by the CBDT.
