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 Chennai held that additions made towards disallowance u/s. 14A r.w.r. 8D of the I.T. Rules, 1962 to book profit computed u/s. 115JB(2) of the Income Tax Act is unsustainable.
ITAT Mumbai held that disallowance u/s 14A untenable as AO has mechanically applied rule 8D without having recorded his satisfaction or examining the nature of investments whether they have yielded any exempt income or not.
ITAT Bangalore held that expenditure towards Employees Stock Option Plan (ESOP) is allowable deduction u/s 37 of the Income Tax Act.
ITAT Ahmedabad held that draft assessment order u/s 143(3) read with section 144C of the Income Tax Act passed on a non-existent company is null and void.
ITAT Mumbai held that provisions of Chapter X cannot be invoked for making a TP adjustment in case of Advertisement, marketing and promotion (AMP) expenses.
ITAT Bangalore held that as professional and consultation charges & purchase of fixed assets are capitalized in the books of accounts, it should not be considered for computation of proportionate TP adjustment.
ITAT Hyderabad held that FCCDs are debt hence interest paid/ payable on FCCDs in to be computed by applying LIBOR plus 200 basis points.
ITAT Delhi held that payment received in the nature of Business Profit cannot be brought to tax in India in absence of Permanent Establishment in India.
Telangana High Court held that writ jurisdiction under Article 226 of the Constitution of India not invocable as adequate and effective alternative remedy under Section 144C of the Act by way of filing objections before the Dispute Resolution panel available to the petitioner.
Final order passed by AO is beyond limitation period provided u/s 144C of Income Tax Act, hence, same is liable to be declared as null & void
