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 there is no provision regarding establishment of virtual service PE under India-Singapore DTAA and hence physical rendition of service in India is required under India-Singapore DTAA as per present service PE.
ITAT Kolkata held that foreign Associated Enterprises are least complex entities and accordingly can be treated as tested parties for comparability analysis of international transaction.
ITAT Mumbai held that business restructuring entered into by an enterprise with its associated enterprise for eliminating duplicate corporate procedures falls within the ambit of “international transaction” as defined in section 92B of the Income Tax Act.
ITAT Bangalore held that if the duration of software license is less than two years, then it should be treated as revenue expenditure and if the duration is more than two years, then it should be treated as capital expenditure.
Detailed analysis of Finastra International Financial Systems PTE Ltd. Vs ACIT(International Taxation) case where ITAT Delhi ruled that software sales to Indian entities are not taxable under Article 12(3) of India-Singapore DTAA.
Delhi High Court judgment in CIT vs. RELX Inc clarifies legal database subscriptions aren’t copyright transfers or royalty. Insights on taxation implications.
Madras High Court quashes tax assessment order due to exceeding time limit for issuing the order after receiving directions from Dispute Resolution Panel. This case highlights the importance of adhering to prescribed timelines in tax assessments.
Madras High Court rules draft assessment order must be treated as show cause notice due to lack of opportunity to respond. This decision protects taxpayer rights and ensures fair tax assessments in India.
Explore the Delhi High Court judgment in CIT Vs S.A. Chitra Ventures Ltd. Understand the limitations on AO’s jurisdiction without income variation in draft assessment orders.
ITAT held that taxation should be based on real income. It found that the AO’s attempt to tax hypothetical income was unjustified. Furthermore, it was established that the credit note adjustments made for benchmarking purposes were legitimate and in accordance with the tax provisions.
