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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 198 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 123 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


Proviso to Section 56(2)(vii)(b): Stamp Duty Value on Date of Agreement applies

February 19, 2024 6645 Views 0 comment Print

Explore the details of Shyamkumar Madhavdas Chugh Vs ACIT case at ITAT Delhi. Analysis of additions, considerations, and legal perspectives leading to the verdict.

Sale outside India; No tax liability in India: ITAT Delhi

February 18, 2024 1635 Views 0 comment Print

Read the detailed analysis of the ITAT Delhi order regarding the taxability of income from offshore supplies of plants and equipments in the case of Air Liquide Global EC Germany GMBH Vs ACIT.

Delhi HC Orders Tax Refund Re-Computation for Reader’s Digest India

February 15, 2024 969 Views 0 comment Print

Delhi High Court directs re-computation of income tax refund for Reader’s Digest India, addressing issues with refund adjustments and statutory interest.

No Provision to Extend 30 Day Limit for Objecting to Draft Income Tax Assessment Order

January 26, 2024 2481 Views 1 comment Print

Kerala High Court rules no provision to extend the 30-day limit for filing objections against draft assessment orders under the Income Tax Act. Details and implications.

Section 144C(4) – Assessment Order Time-Barred if Objections Filed After Limitation: Delhi HC

January 21, 2024 2745 Views 0 comment Print

Delhi ITAT rules on time limitation for Assessment Order under Sec 144C(4). Analysis of objections filing, jurisdiction, and compliance with Income Tax Act. Full order details provided.

Denial of 80IA Benefit in 4th Year Unjustified: Delhi HC

January 10, 2024 966 Views 0 comment Print

Delhi High Court ruling on Income Tax: Department’s U-turn on 80IA deduction in the 4th year deemed unjustified. Case analysis of PCIT vs. BT Global Communications India Pvt. Ltd.

Receipt in terms of Strategic Oversight Services Agreement cannot be termed as royalty

January 6, 2024 1611 Views 0 comment Print

Delhi High Court held that the consideration received in terms of Strategic Oversight Services Agreements (SOSA) cannot be termed as Royalty under Article 12 of the DTAA even if extensive services are rendered which includes access to written knowledge, processes, and commercial information in furtherance of the services.

Section 144C(3) r.w.s. 144C(4) Mandate AO to Conclude Assessment within One Month if Assessee Accepts Draft Order or Fails to File Objection

November 26, 2023 4482 Views 0 comment Print

Dilipkumar Jashbai Patel Vs ACIT (ITAT Ahmedabad)- Section 144C(3) r.w.s. 144C(4) Mandate AO to Conclude Assessment within One Month if Assessee Accepts Draft Order or Fails to File Objection

Passing of assessment order two years after Dispute Resolution Panel direction is time barred

November 20, 2023 1494 Views 0 comment Print

Bombay High Court held that assessment order passed by Faceless Assessing Officer (FAO) two years after the Dispute Resolution Panel (DRP) directions, is time barred and cannot be sustained.

Delhi HC Upholds ITAT’s Decision on Comparables for Arm’s Length Price

November 14, 2023 987 Views 0 comment Print

Delhi High Court supports ITAT’s verdict on the selection of comparables for determining the Arm’s Length Price of an international transaction. Get insights on PCIT vs Chrys Capital

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