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...
The ITAT found inconsistencies in the selection and rejection of comparable companies for determining the arm’s length price of international transactions. It directed inclusion and exclusion of specific comparables and partly allowed the assessee’s appeal.
The Tribunal condoned the delayed appeal filing after finding sufficient cause and allowed the matter to proceed. It also clarified that reassessment jurisdiction remains valid despite arguments regarding faceless assessment provisions.
The Delhi ITAT held that notifications issued under TOLA extending limitation periods applied only to specified statutes and not to Black Money Act assessments. As a result, the assessment order passed beyond the statutory deadline was quashed.
The Delhi ITAT held that receipts from sale and restricted use of standard cybersecurity software could not be taxed as Fees for Technical Services. The Tribunal relied on judicial precedents dealing with standardised technology offerings.
The Tribunal held that transfer pricing analysis should focus on international transactions rather than entity-level profitability where segmental data is available. The case was remanded for fresh consideration of comparables and ALP determination.
Additions made by attributing the commission income earned by PSPL as undisclosed income of the Assessees were held unsustainable in law and were directed to be deleted across all relevant assessment years as Revenue had failed to establish inflation of purchase prices; accrual of PSPL’s commission income to assessees; any flow back of funds to the Assessees; or that PSPL was a sham or fictitious entity.
Mumbai ITAT held that an order labelled as a draft assessment order loses its character if accompanied by demand notices and penalty initiation. Failure to comply with Section 144C renders the assessment void and without jurisdiction.
The Tribunal restored the matter to the Assessing Officer after finding that transfer pricing adjustments may have been added twice while computing the assessee’s income. The issue requires fresh examination after granting an opportunity of hearing.
The High Court held that issuing a demand notice along with a draft assessment order violated the mandatory procedure under Section 144C. Since the assessment had effectively been completed at the draft stage, the reassessment orders were quashed.
ITAT Delhi held that television channel and content owner companies could not be compared with a content distribution business. The Tribunal directed exclusion of such entities from the transfer pricing comparables list.
