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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


Section 271(1)(c) penalty unjustified without Income Concealment or Inaccurate Particulars

October 3, 2023 3972 Views 0 comment Print

ITAT Delhi held that imposition of penalty u/s. 271(1)(c) of the Income Tax Act unsustainable in absence of any concealment of income or furnishing inaccurate particulars of income by the assessee.

‘Non-cooperative attitude’ alone cannot justify penalties: ITAT Delhi

October 2, 2023 1125 Views 0 comment Print

Explore the case of Alankit Imaginations Ltd vs. DCIT (ITAT Delhi), where penalties were challenged. Learn why a ‘non-cooperative attitude’ alone cannot justify penalties.

Once assessment order is passed Dispute Resolution Panel not empowered to give direction

September 28, 2023 3462 Views 0 comment Print

Bombay High Court held that Dispute Resolution Panel (DRP) could give directions only in pending assessment proceedings. Once assessment order is passed, DRP has not power to pass any direction.

Long term capital gain and indexation accepted for one co-owner needs to be allowed for other co-owner too

September 27, 2023 1269 Views 0 comment Print

ITAT Delhi held that once long term capital gain along with cost of acquisition and indexation accepted in the hands of one of the co-owner of the property, the same needs to be allowed/ accepted for other co-owner of the property too.

ITAT Grants 30% Depreciation on Philips India’s Business-Owned Moulds

September 21, 2023 1674 Views 8 comments Print

Read the full text of the ITAT Kolkata order in the case of Philips India Limited vs. ACIT regarding the grant of 30% depreciation on business-owned moulds.

Benefit of indexed cost of acquisition available based on payments dates

September 15, 2023 2322 Views 0 comment Print

ITAT Delhi held that held that benefit of indexed cost of acquisition should be available to assessee based on payments made. Accordingly, AO directed to re-compute gain.

Payment of guarantee fees to holding company for loan advanced to third party is deductible u/s. 37

September 15, 2023 1587 Views 0 comment Print

ITAT Mumbai held that guarantee fees paid to holding company for loan advanced by assessee to third party is commercial/ business expediency and hence allowable as deduction under Section 37 of the Income Tax Act.

Payment towards interconnectivity utility charges from Indian customers not taxable as Royalty

September 9, 2023 1599 Views 0 comment Print

ITAT Bangalore held that payments received towards interconnectivity utility charges from Indian customers / end users cannot be considered as Royalty to be brought to tax in India under section 9(1)(vi) of the Income Tax Act and also as per DTAA.

Fees for live and non-live transmission right not taxable as royalty

September 3, 2023 1230 Views 0 comment Print

ITAT Delhi held that as there is no copyright on live events, the license fees for live and non-live transmission right cannot be taxed as royaty in terms of section 9(1)(vi) of the Income Tax Act. Accordingly, addition deleted.

AO not empowered to withdraw or modify or substitute assessment order passed by him

September 2, 2023 2262 Views 0 comment Print

ITAT Delhi held that law does not confer any power on the Assessing Officer to either withdraw or modify or substitute one assessment order passed by him earlier with another assessment order subsequently.

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