Follow Us:

Section 144C

Latest Articles


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 105 Views 0 comment Print


IT Support Payments Not FTS under Article 12 of India-Netherlands DTAA

May 18, 2024 1536 Views 0 comment Print

In a landmark ruling, ITAT Mumbai provides relief to Shell IT, asserting that payments for IT support aren’t considered FTS under India-Netherlands DTAA.

Manufacturing Segment Transaction Benchmarking: ITAT Upholds TNMM Method Over CUP

May 10, 2024 774 Views 0 comment Print

Read the full text of ITAT Mumbai’s order in the case of LANXESS India Pvt Ltd vs DCIT, upholding TNMM method over CUP for benchmarking export transactions under manufacturing segment.

Section 44BB does not override provisions related to PE or DTAA benefits

May 9, 2024 792 Views 0 comment Print

Read the detailed analysis of Computer Modelling Group Ltd. vs. ACIT (ITAT Delhi) regarding interest leviable from the assessee for short payment of tax due to payer’s TDS default before FY 2012-2013.

Consider Volume Discount & Geographic Price Variation in TP Adjustment: ITAT Ahmedabad

May 8, 2024 873 Views 0 comment Print

Ahmedabad ITAT’s order in Atul Limited vs DCIT case discusses TP adjustments, volume discount, geography adjustments, and more. Detailed analysis provided.

Ahmedabad ITAT Clarifies Letter of Credit vs. Bank Guarantee in Transfer Pricing Dispute

May 8, 2024 1671 Views 0 comment Print

In a detailed analysis of Axis Bank Limited Vs ACIT case, Ahmedabad ITAT explains the difference between a Letter of Credit and Corporate Guarantee, resolving disallowance disputes.

Bullion Purchases: LBMA Rates vs. KITCO and Reuters for ALP

May 6, 2024 732 Views 0 comment Print

ITAT considered the justification provided by the assessee, which referenced KITCO and Reuters databases for determining transaction prices. However, the Transfer Pricing Officer (TPO) argued that the London Bullion Market Association (LBMA) should be the primary source for estimating bullion trading prices.

Post-filing Corrections to Form 35A cannot be treated as filed beyond time limit

May 5, 2024 1224 Views 0 comment Print

ITAT found that the original Form 35A was filed within the stipulated time and ruled that the correction made thereafter should not be considered late.

STCL Taxable at 15% Can be set-ff against STCG Taxable at 30%: ITAT Mumbai

May 5, 2024 1635 Views 0 comment Print

Explore the detailed analysis of JS Capital LLC Vs ACIT (ITAT Mumbai) regarding the offsetting of Short Term Capital Loss (STCL) against Short Term Capital Gain (STCG) under section 70(2) of the Income Tax Act.

ITAT allows deduction of interest paid on Perpetual Non-Convertible Debentures (PNCD)

April 21, 2024 1338 Views 0 comment Print

ITAT Mumbai grants relief to Tata Steel Limited, allowing deduction of interest paid on Perpetual Non-Convertible Debentures (PNCD) under section 36(1)(iii) of the Act. 

Stay on Income Tax Recovery can be granted if 20% Tax Already been paid: Kerala HC

April 19, 2024 1500 Views 1 comment Print

Kerala High Court’s judgment on applicability of CBDT Circular regarding deposition of assessed tax when appeal lies only before ITAT. Analysis and conclusion provided.

Search Post by Date
July 2026
M T W T F S S
 12345
6789101112
13141516171819
20212223242526
2728293031