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...
ITAT Delhi held that long term capital gain on sale of shares in case of the assessee company, being resident of Mauritius, is not liable to be taxed in India.
Delhi High Court held that the receipts from Indian customers for services provided outside Indian Territory, in connection with use or right to use of process or equipment by the assessee company, cannot be taxed as royalty as per section 9(l)(vi) of the Income Tax Act.
ITAT Ahmedabad held that benefit demonstrated in form of reduced interest rate on account of guarantee, thus, payment of guarantee fee justifiable. Accordingly, TP adjustment on account of the guarantee fee payment to AE deleted.
ITAT Chennai restored the matter back to the file of AO for re-adjudication as additional ground raised by the assessee in appeal were not taken up before lower authorities.
Discover how Section 44C of the Income Tax Act, 1961, governs the deduction of head office expenses for non-resident businesses in India.
Read the full text of the ITAT Delhi order on Cricket Australia vs. ACIT (International Taxation). Analysis includes why license fees from live cricket match transmissions held in Australia are not considered royalty under Indian tax laws.
Delhi ITAT rules in Ares Diversified Vs ACIT that rejection of belated objections by DRP does not extend the limitation for passing final assessment U/s 144(4).
Read about Bombay High Courts decision upholding ITAT’s order directing Vodafone India to deposit Rs.230 crores to stay income tax demands, analyzing the legal implications and challenges faced.
Read the full text of the Delhi ITAT order on Denso (Thailand) vs ACIT, discussing tax liability for technical services under India-Thailand DTAA, absence of FTS clause, and PE considerations.
ITAT emphasized that under the accrual system, provisions for outstanding expenses can indeed be recognized based on estimates and do not require exact certainty at the time of accrual. The fact that the statutory auditors had approved the financial statements without qualification further supported Culver Max’s position that these provisions represented ascertained liabilities within the framework of accrual-based accounting.
