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Section 144C

Latest Articles


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 906 Views 0 comment Print


Latest Judiciary


Company with Turnover 10 times of Assessee’s Cannot Be Included as Comparable: ITAT Hyderabad

Income Tax : ITAT Hyderabad directed to exclude companies having turnover of more than or less than 10 times of the turnover of the assessee fr...

August 12, 2024 156 Views 0 comment Print

Direction given by Tribunal to AO to re-examine issue cannot be disregarded: Delhi HC

Income Tax : Delhi High Court held that once the Tribunal had called upon the AO to examine the issue afresh, the said direction could not have...

August 7, 2024 219 Views 0 comment Print

Tax not leviable on LTCG earned by Mauritius company on sale of share: ITAT Delhi

Income Tax : ITAT Delhi held that long term capital gain on sale of shares in case of the assessee company, being resident of Mauritius, is not...

July 31, 2024 195 Views 0 comment Print

Receipts from Indian customers for services provided outside India relating to right to use of process not taxable: Delhi HC

Income Tax : Delhi High Court held that the receipts from Indian customers for services provided outside Indian Territory, in connection with u...

July 29, 2024 369 Views 0 comment Print

Guarantee fee to AE resulted into reduced interest rate hence TP adjustment unjustified: ITAT Ahmedabad

Income Tax : ITAT Ahmedabad held that benefit demonstrated in form of reduced interest rate on account of guarantee, thus, payment of guarantee...

July 26, 2024 135 Views 0 comment Print


ITAT allows deduction of interest paid on Perpetual Non-Convertible Debentures (PNCD)

April 21, 2024 603 Views 0 comment Print

ITAT Mumbai grants relief to Tata Steel Limited, allowing deduction of interest paid on Perpetual Non-Convertible Debentures (PNCD) under section 36(1)(iii) of the Act. 

Stay on Income Tax Recovery can be granted if 20% Tax Already been paid: Kerala HC

April 19, 2024 597 Views 1 comment Print

Kerala High Court’s judgment on applicability of CBDT Circular regarding deposition of assessed tax when appeal lies only before ITAT. Analysis and conclusion provided.

Final Assessment Order Invalid without Draft Section u/s 144C(1) Order: ITAT Mumbai

April 12, 2024 1185 Views 0 comment Print

ITAT Mumbai quashes assessment order in Welspun Global Brands Ltd Vs DCIT case. AO failed to follow Sec 144C(1) of Income Tax Act, rendering order invalid.

After initiation of resolution process appeal not maintainable if not filed by IRP

April 11, 2024 279 Views 0 comment Print

Since the appellant hadn’t filed the appeal through the Interim Resolution Professional as required under the resolution process, the ITAT deemed the appeal not maintainable and dismissed it.

AO Must Adhere to TPO’s ALP in International Transactions: Delhi HC

April 11, 2024 540 Views 0 comment Print

Delhi High Court rules AO can’t deviate from Transfer Pricing Officer’s determined Arm’s Length Price (ALP) in international transactions, upholding assessee’s writ petition.

Madras HC Quashes Income Tax Assessment Order Amid Pending Objections before DRP

April 10, 2024 261 Views 0 comment Print

Read about the Madras High Court’s decision to quash an Income Tax assessment order issued while objections were pending before the Dispute Resolution Panel.

Order passed without implementing direction of DRP is void-ab-initio: ITAT Delhi

April 8, 2024 702 Views 0 comment Print

ITAT Delhi held that AO is bound to follow the directions of DRP. Accordingly, final assessment order passed by AO without implementing direction of DRP makes the assessment order void-ab-initio.

Investment in Shares is Capital Account Transaction, Not Income: Delhi HC

March 26, 2024 594 Views 0 comment Print

Delhi High Court rules investment in shares as capital account transaction, not income, in AL Amin Investments Limited Vs ACIT case. Analysis & judgment here.

India-Thailand DTAA: Non-Resident’s Fee for Technical Services Exempt from Taxation

March 24, 2024 2328 Views 0 comment Print

Discover the ITAT Delhi ruling on taxing income from providing business support services to Indian group entities. Analysis of Solvay Asia vs. DCIT case under India-Thailand DTAA.

Payment towards interconnect usage charges to foreign telecom operators not taxable in India: ITAT Mumbai

March 23, 2024 450 Views 0 comment Print

ITAT Mumbai held that the payment made towards interconnect usage charges to foreign telecom operators does not accrue or arise in India and in the absence of any permanent establishment in India could not be brought to tax in India under Article 7 of DTAA.

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