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Section 144C

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Retrospective Amendments under Budget 2026 – Rectification, Revision, Reassessment Options before Tax Authorities

Income Tax : Budget 2026 introduces sweeping retrospective amendments affecting limitation, reassessment jurisdiction, DIN validity, and TPO ti...

February 26, 2026 6498 Views 1 comment Print

Special vs General: Time Limit Conflict between Section 144C(13) and Section 153 of Income Tax Act, 1961

Income Tax : Courts are divided on whether the DRP-specific deadline under Section 144C(13) overrides the general assessment time bar in Sectio...

December 16, 2025 3135 Views 0 comment Print

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 3027 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 17592 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 7485 Views 0 comment Print


Latest News


Income from Vessel Operations Taxable Under India-Norway DTAA: ITAT Delhi

Income Tax : Delhi ITAT allows Sanco Holding, a Norwegian company, to compute income from bareboat charter of seismic vessels under Article 21(...

October 17, 2025 888 Views 0 comment Print


Latest Judiciary


Section 143(2) Notice & Valid Draft Assessment Mandatory U/s 144C: ITAT Mumbai

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 ...

July 5, 2026 192 Views 0 comment Print

Amalgamation Goodwill Eligible for Depreciation; Notional Interest on AE Receivables Deleted: ITAT Delhi

Income Tax : ITAT held that goodwill arising on amalgamation qualifies as a depreciable intangible asset. It also deleted the TP adjustment on ...

July 4, 2026 117 Views 0 comment Print

Captive Service Provider Entitled to Risk Adjustment; Nil ALP for Proven Intra-Group Services Rejected: ITAT Delhi

Income Tax : ITAT Delhi held that documentary evidence established receipt of intra-group administrative support services and that the 5% marku...

July 4, 2026 117 Views 0 comment Print

ITAT Delhi Excludes TPO Comparables for Functional Dissimilarity

Income Tax : ITAT excluded EDCIL, Just Dial, Info Edge and India Exposition Mart as transfer pricing comparables due to functional differences ...

July 1, 2026 153 Views 0 comment Print

ITAT Deletes Brand Promotion TP Adjustment as Issue Was Already Settled in Earlier Years

Income Tax : ITAT upheld taxation of IPS and CEV subsidies following the Section 2(24) amendment, while partly allowing the appeal on other iss...

July 1, 2026 99 Views 0 comment Print


Section 270AA Penalty Immunity Application Cannot Be Rejected on Insufficient Grounds or Vague SCNs

June 13, 2024 3081 Views 0 comment Print

Delhi High Court judgment on GE Capital vs. DCIT, distinguishing under-reporting and misreporting as separate offenses, resulting in quashed penalty. Full text analysis.

Guarantee Commission Charges taxable in India as “other income” under Article 23(3) of Indo-UK DTAA

June 12, 2024 1581 Views 0 comment Print

Guarantee commission charges received by a foreign parent company from its Indian subsidiaries were taxable in India, not as interest but as “other income” under Article 23(3) of the DTAA.

CRM Services Receipts Not Taxable as Royalty or FTS: ITAT Delhi

June 4, 2024 879 Views 0 comment Print

In the case of Salesforce.com Singapore Pte Ltd. vs ACIT, ITAT Delhi ruled that receipts from CRM services aren’t taxable in India as royalty or FTS under the Income-tax Act or India-Singapore DTAA.

TPO fails to Apply Industry Filter while Determining ALP of Interest: ITAT Deletes addition

May 31, 2024 909 Views 0 comment Print

ITAT Delhi dismisses DCIT’s appeal against DLF Urban Pvt. Ltd. TPO failed to apply industry filter for ALP of interest, resulting in the deletion of Rs. 6.29 crores addition.

Assessee Can Avail DTVSV Act Benefits Even if Appeal Limitation Period Not Expired

May 31, 2024 4824 Views 0 comment Print

Assessee can’t be obstructed from availing of the benefits of the Direct Tax Vivad se Vishwas Act, 2020 (DTVSV Act) even where the time limit for an appeal had not expired as DTVSV Act aspired to finally free the tax arrears locked in the litigation combat for ages and ultimately ensures timely collection of tax.

After TPO’s Order, AO Obligated to Follow Section 92CA(4) for Assessment

May 30, 2024 3231 Views 0 comment Print

The Delhi High Court ruled that once a TPO issues an order, the AO must pass an assessment order per Section 92CA(4) of the Income Tax Act.

Section 144C(13): AO Must Finalize Assessment within one month from the month of DRP’s Directions

May 27, 2024 3408 Views 0 comment Print

Learn about the Chennai ITAT ruling in Conferencecall Services India Pvt. Ltd. vs. DCIT, where a final assessment made after one month of DRP directions was declared time-barred.

Employee Salary Reimbursement Not Taxable as FTS under India-Japan DTAA

May 24, 2024 1455 Views 0 comment Print

Understand the grounds of appeal in the case against the final assessment order under the Income Tax Act, 1961, for AY 2017-18, involving taxability of employee cost reimbursements and more.

Non-resident’s salary/allowances for services rendered abroad not taxable in India

May 23, 2024 5739 Views 0 comment Print

ITAT Delhi rules non-resident’s salary for services rendered abroad not taxable in India, providing significant relief under India-Australia DTAA.

Final Order U/S 144C not appealable if Assessee not filed objection against  draft assessment order

May 20, 2024 11742 Views 0 comment Print

Learn about the case of Skybridge Solutions Private Limited vs. DCIT (ITAT Hyderabad) regarding the final assessment order passed under Section 144C without objection against the draft assessment order. Understand the implications and key takeaways from the judgment.

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