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...
In present facts of the case, it was observed by the Tribunal that only Assessee could sign Form number 35A prescribed under Income Tax (Dispute Resolution Panel) Rules, 2009.
In present facts of the case, the Tribunal held that Assessment Order issued without DIN is null and void as it is in violation of CBDT Circular No. 19/2019 dated 1 4th August, 2019.
ITAT Delhi held that disallowance of staff welfare expenditure on the adhoc basis unsustainable as AO failed to establish as to who the expenses are not incurred for business purpose.
ITAT Delhi permits a Section 54 deduction that wasn’t claimed in original or revised returns. The case highlights the powers of appellate authorities.
ITAT Mumbai held that cost reimbursement received towards providing support services is taxable as Fees for Technical Services (FTS) both under Section 9(1) (vii) of the Act as well as Article 12(4) of the Double Taxation Avoidance Agreement.
ITAT Delhi held that depreciation on Solar Power Plant installed on office building which is part of factory and electricity so generated is used for factory only is allowable as per provision of law.
ITAT Delhi held that addition on account of attributing income from offshore supplies to permanent establishment in India unjustified in case of loss.
ITAT Mumbai ruled that an assessment order against a non-existent entity (Pipal Research Analytics) is invalid. Insight into Crisil Ltd vs ACIT case.
ITAT Mumbai imposes Rs. 10,000 cost on Hunt International Investments LLC for non-response to notices under section 142(1). Details on the case inside.
Analysis of ITAT Delhi’s ruling in Bushra Javed Vs ACIT: Indexation benefits for acquisition costs based on payment year. Read the full legal insight here.
