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...
FedEx Express Transportation and Supply Chain Services (India) Private Limited Vs DCIT (ITAT Mumbai) The case of FedEx Express Transportation and Supply Chain Services (India) Private Limited Vs DCIT (ITAT Mumbai) revolves around the validity of a Transfer Pricing order, draft assessment order, and the consequent final assessment order. The key contention is whether the […]
ITAT Delhi held that passing of final assessment order without complying with the terms of section 144C of the Income Tax Act, 1961 is untenable in law.
In a significant ruling, ITAT Ahmedabad declares an assessment order void, passed in the name of a non-existent entity after a court-approved amalgamation.
Held that the amounts received for the use of transponder of tele-communication service charges are not royalty under section 9(1)(vi) of the Income Tax Act and also under Article 12(8) of Indo Netherland DTAA.
Delhi High Court invalidates final assessment order due to failure to pass a draft assessment order in Sinogas Management PTE LTD vs. DCIT case.
In PCIT vs. Hellmann Worldwide Logistics India Pvt. Ltd case, Delhi High Court upholds appellate authorities’ right to choose a different transfer pricing method.
ITAT Mumbai held that there was no express arrangement / agreement between the assessee and the AE for incurring advertisement, marketing and promotional expenses (AMP) to promote the brand of the AE and hence the said transactions would not constitute international transaction relating to AMP expenditure. Thus, TP adjustment deleted.
Bombay High Court held that failure to pass a draft assessment order under section 144C(1) of the Income Tax Act results in rendering the final assessment as one without jurisdiction.
ITAT Delhi held that payments received by the assessee qualifies as Fees for Technical Services (FTS) under sub-clause (4) of Article 12 of Indo – Singapore DTAA and hence rightly brought to tax @10%.
Read how ITAT Delhi deleted ALP adjustment in STEAG Energy Services vs. ACIT case, as it falls within tolerance band of +/- 5% under Section 92C(2) of Income Tax Act.
