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 Amritsar held that transfer of REC (Renewable Energy Certificate) is capital in nature and not liable to tax under business income as the income is offshoot from environmental concern not from offshoot of business concern.
ITAT Bangalore held that pre-clinical laboratory services rendered by the assessee (non-resident) to its customers in India would not be chargeable to tax in India as the technical services rendered by the affiliates do not “make available” technical knowledge, experience, skill, know-how or process while preparing these reports for their, Indian customers/ clients.
ITAT Mumbai held that determination of Arm’s Length Price (ALP) of intra group services at Rs. Nil is not justified as the assessee has maintained a reasonably sound documentation of intra group services.
ITAT Mumbai held that TPO was correct in concluding that the rate at which loan is taken by the Appellant cannot be taken as internal CUP to benchmark the loan given by the Appellant to its AE as there is a difference in credit rating of the Appellant and its AE.
ITAT Mumbai held that the TPO is not correct in arriving at the ALP as NIL on the ground that the need and benefit test is not satisfied by the assessee without giving any contrary findings with regard to the various documents including the TP study submitted by the assessee.
ITAT Delhi held that statue doesn’t empower the Assessing Officer to withdraw or modify or substitute the assessment order passed under Section 143(3) of the Income Tax Act with another assessment order.
ITAT Delhi held that the receipts from centralised service income are not taxable as Fees for Technical Services (FTS)/ Fees for included Services (FIS) under Article 12(4)(a) of India-USA DTAA.
ITAT Mumbai’s decision in case of DCIT vs KEC International Limited, where a 0.6% arm’s length rate was established for corporate guarantee fees, influencing future transfer pricing adjustments.
ITAT Delhi held that as Permanent Establishment (PE) exists, interest income being connected to the PE, has to be treated as business profit under Article 7 of the treaty. Accordingly, expenses incurred has to be set off against the interest income.
ITAT Mumbai held that FCCB i.e. Foreign Currency Convertible Bond expenses included as part of FCCB premium expenses is allowable.
