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...
ITAT Mumbai imposes Rs. 10,000 cost on Hunt International Investments LLC for non-response to notices under section 142(1). Details on the case inside.
Analysis of ITAT Delhi’s ruling in Bushra Javed Vs ACIT: Indexation benefits for acquisition costs based on payment year. Read the full legal insight here.
ITAT Delhi held that the receipts from offshore supply of rolling stock (train sets) cannot be taxable in India as the transfer of title over the goods has taken place outside India.
ITAT Mumbai held that as per section 92CA of the Income Tax Act, TPO can pass the order at any time before 60 days prior to the date on which period of limitation referred u/s 153 expires. TPO order passed after the prescribed time limit is non-est and barred by limitation.
ITAT Delhi held that there is no justification of adopting lower Fair Market Value (FMV) merely on the basis of DVO report as DVO has failed to consider the specific features of the property commanding higher value.
ITAT Mumbai held that services provided by Indian Company to company registered in Isle of Man (i.e. non-resident company) under Canvasser Agent Agreement, on principal-to-principal basis not taxable in India.
ITAT Delhi held that receipts from disaster recovery playout services and disaster recovery up-linking services are not in the nature of Fee for Technical Service (FTS) as envisaged under Article 12(4)(a) of India-Singapore DTAA.
ITAT Mumbai held that as per section 92CA(3) TPO order should be passed before 60 days prior to the date prescribed u/s 153 of the Act. Accordingly, in present case, TPO order passed on 30/01/2015 instead of 29/01/2015 is non-est and liable to be quashed as being barred by limitation.
This article analyzes how Section 153’s time limit prevails over Section 144C’s assessment time limit, based on the case of Shelf Drilling Ron Tappmeyer Limited Vs ACIT in Bombay High Court.
ITAT Delhi held that rendering cloud computing services/ Amazon Web Services (AWS Services) cannot be held to be liable to tax in India either as royalty or as Fees for Technical Services (FTS)/ Fees for Included Services (FIS).
