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 : The ITAT observed that mere remote access to customer-owned systems does not satisfy the disposal and permanence tests required fo...
Income Tax : The ITAT Delhi ruled that reimbursement of software costs to foreign AEs on a cost-to-cost basis could not be treated as a profit-...
Income Tax : Tribunal found the DRP’s order cryptic and lacking proper analysis on similarity of business activities between the assessee and...
Income Tax : The Tribunal ruled that margins agreed under a Bilateral Advance Pricing Agreement may be used for non-covered AEs when transactio...
Income Tax : Delhi ITAT directed exclusion of a comparable company engaged in video conferencing solutions after noting that the DRP had alread...
ITAT Delhi held that royalty payment and R&D cess on royalty is interlinked. As royalty payment is allowed as revenue expenditure, R&D cess is also allowable as revenue expenditure.
ITAT Mumbai held that income earned from offshore supply of escalators and elevators is not taxable in India as assesse didn’t carried out any operations in India.
ITAT Mumbai held that the assessment order passed in variation of the procedures prescribed u/s. 144B of the Income Tax Act would render the assessment order as non est.
ITAT Delhi held that the amount of received in the arbitration settlement is related to project office of the assessee company in India. Accordingly, the same is taxable in India.
ITAT Mumbai held that issuance of draft assessment order along with the demand notice is in violation of provisions of section 144C of the Income Tax Act and hence bad in law.
ITAT Delhi held that assessment order passed in violation of the directions of Dispute Resolution Penal (DRP) is against the provisions of sub-section (10) and (13) of section 144C of the Act and hence liable to be quashed
Bombay High Court held that Circular No.5-2012 dated 1 August 2012 will not be applicable to the instant case pertaining to AY 2008-09. Law to be applied is the one that is in force in the relevant assessment year unless otherwise provided expressly or by necessary implication. Accordingly addition unsustainable.
ITAT Bangalore held that disallowance merely considering the provisions of section 144C(8) of the Income Tax Act without verification of details furnished by the assessee is unsustainable in law.
ITAT Delhi held that transactions relating to currency swap contracts cannot be considered to be in the nature of speculative transaction covered u/s. 43(5) of the Act. Accordingly, the same is allowable as deduction u/s. 36(1)(iii) of the Act.
ITAT Mumbai held that as per section 92CA (3A) of the Income Tax Act Transfer Pricing Officer (TPO) is required to pass an order within a period of 60 days prior to the date of completion of assessment as per section 153 of the Income Tax Act. Order passed after the date will be barred by limitation.
