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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 117 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


Specified domestic transactions adjustment invalid after 01.04.2017

September 2, 2023 804 Views 0 comment Print

Finance Act, 2017 removed clause (i) of section 92BA, effectively nullifying any decisions made by the Assessing Officer under this section. Reference to the TPO under section 92CA also becomes invalid

Software licence fee reimbursement not taxable as no Permanent Establishment in India

September 1, 2023 1575 Views 0 comment Print

ITAT Delhi held that software licence fee received as reimbursement, in absence of a Permanent Establishment in India, is not taxable. Accordingly, addition towards the same deleted.

Only assessee can sign Form number 35A prescribed under Income Tax (Dispute Resolution Panel) Rules, 2009

August 31, 2023 11337 Views 1 comment Print

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.

Communication relating to assessments, appeals, orders without DIN are null & void

August 31, 2023 1329 Views 0 comment Print

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.

Disallowance of staff welfare expenditure resorting to adhoc base unsustainable

August 29, 2023 2829 Views 0 comment Print

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 allows Section 54 Deduction Not Claimed in Original or Revised Return

August 29, 2023 1602 Views 0 comment Print

ITAT Delhi permits a Section 54 deduction that wasn’t claimed in original or revised returns. The case highlights the powers of appellate authorities.

Cost reimbursement for support services taxable as Fees for Technical Services

August 24, 2023 1830 Views 0 comment Print

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.

Depreciation eligible on Solar Power Plant as electricity utilized for factory operations

August 24, 2023 22425 Views 0 comment Print

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.

Addition of Offshore Supply Income to PE in India on account of loss Unjustified

August 22, 2023 867 Views 0 comment Print

ITAT Delhi held that addition on account of attributing income from offshore supplies to permanent establishment in India unjustified in case of loss.

Assessment order against a non-existing entity post amalgamation is invalid

August 22, 2023 714 Views 0 comment Print

ITAT Mumbai ruled that an assessment order against a non-existent entity (Pipal Research Analytics) is invalid. Insight into Crisil Ltd vs ACIT case.

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