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 directs re-computation of income tax refund for Reader’s Digest India, addressing issues with refund adjustments and statutory interest.
Kerala High Court rules no provision to extend the 30-day limit for filing objections against draft assessment orders under the Income Tax Act. Details and implications.
Delhi ITAT rules on time limitation for Assessment Order under Sec 144C(4). Analysis of objections filing, jurisdiction, and compliance with Income Tax Act. Full order details provided.
Delhi High Court ruling on Income Tax: Department’s U-turn on 80IA deduction in the 4th year deemed unjustified. Case analysis of PCIT vs. BT Global Communications India Pvt. Ltd.
Delhi High Court held that the consideration received in terms of Strategic Oversight Services Agreements (SOSA) cannot be termed as Royalty under Article 12 of the DTAA even if extensive services are rendered which includes access to written knowledge, processes, and commercial information in furtherance of the services.
Dilipkumar Jashbai Patel Vs ACIT (ITAT Ahmedabad)- Section 144C(3) r.w.s. 144C(4) Mandate AO to Conclude Assessment within One Month if Assessee Accepts Draft Order or Fails to File Objection
Bombay High Court held that assessment order passed by Faceless Assessing Officer (FAO) two years after the Dispute Resolution Panel (DRP) directions, is time barred and cannot be sustained.
Delhi High Court supports ITAT’s verdict on the selection of comparables for determining the Arm’s Length Price of an international transaction. Get insights on PCIT vs Chrys Capital
FedEx Express Transportation and Supply Chain Services (India) Private Limited Vs DCIT (ITAT Mumbai) The case of FedEx Express Transportation and Supply Chain Services (India) Private Limited Vs DCIT (ITAT Mumbai) revolves around the validity of a Transfer Pricing order, draft assessment order, and the consequent final assessment order. The key contention is whether the […]
ITAT Delhi held that passing of final assessment order without complying with the terms of section 144C of the Income Tax Act, 1961 is untenable in law.
