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Section 144C

Latest Articles


Taxpayers Concerned as Assessment Orders Deviate from Orders Giving Effect

Income Tax : Taxpayers face challenges when assessment orders don’t reflect DRP directions. Misalignments lead to disputes, rectification iss...

October 4, 2024 2385 Views 0 comment Print

Eyes on Apex Court: Legal Community Awaits Supreme Court’s Verdict on Roca Bathroom Case

Income Tax : The legal community awaits the Supreme Court decision on the Roca Bathroom case, addressing timelines for transfer pricing assessm...

September 5, 2024 9309 Views 0 comment Print

Section 44C of Income Tax Act, 1961 Deduction of head office expenditure in case of Non-residents

Income Tax : Discover how Section 44C of the Income Tax Act, 1961, governs the deduction of head office expenses for non-resident businesses in...

July 19, 2024 3579 Views 0 comment Print


Latest Judiciary


Reopening u/s. 147 based on invalid reasons recorded by AO cannot be sustained: ITAT Hyderabad

Income Tax : ITAT Hyderabad held that reopening of assessment under section 147 of the Income Tax Act on the basis of invalid reasons recorded ...

May 7, 2025 351 Views 0 comment Print

Assuming jurisdiction u/s. 153C beyond block of ten years not tenable-in-law: Delhi HC

Income Tax : Delhi High Court held that since AY 2012-13 falls beyond the block of ten years that are required to be reckoned from the end of t...

May 6, 2025 111 Views 0 comment Print

Revision order u/s. 263 passed in name of non-existent entity cannot be sustained: ITAT Ahmedabad

Income Tax : ITAT Ahmedabad held that revisionary order passed under section 263 of the Income Tax Act in the name of non-existent entity (amal...

May 6, 2025 72 Views 0 comment Print

ITAT Quashes Assessment Order Passed Without Complying Section 144C Provisions

Income Tax : ITAT Delhi quashes final assessment order passed without a mandatory draft order under Section 144C(1), deeming it void from the b...

May 5, 2025 258 Views 0 comment Print

Tax Loss Cannot Be Reduced by Unserved Section 143(1) Intimation: ITAT Ahmedabad

Income Tax : ITAT Ahmedabad rules that a GST intimation under section 143(1) is invalid if not served within the prescribed time limits to the ...

May 5, 2025 1407 Views 0 comment Print


TP assessment by TPO proceeded on incorrect appreciation of nature of service hence matter restored back

October 29, 2024 237 Views 0 comment Print

ITAT Ahmedabad held that the TP assessment carried out by the TPO proceeded on the basis of incorrect appreciation of nature of services availed by the assessee from its AE. Thus, issue of determination of ALP of transactions with AE restored back to TPO.

Mistake apparent pertaining to carry forward and set off of unabsorbed depreciation and business losses could be revised by filing Form 3 under VSV scheme

October 18, 2024 756 Views 0 comment Print

The failure of assessee to make the requisite disclosures in Schedule D would neither detract from the relief which had been accorded by AO nor change the factum of carry forward and set off as forming part of the assessment order.

Passing final assessment order beyond prescribed limit u/s. 144C bad-in-law: Delhi HC

October 16, 2024 330 Views 0 comment Print

The Revenue has filed the present appeal under Section 260A the Income Tax Act, 1961 impugning an order dated 05.01.2024 passed by the Income Tax Appellate Tribunal in ITA No.185/Del/2023 in respect of the assessment year 2013-14.

Taxpayers Concerned as Assessment Orders Deviate from Orders Giving Effect

October 4, 2024 2385 Views 0 comment Print

Taxpayers face challenges when assessment orders don’t reflect DRP directions. Misalignments lead to disputes, rectification issues, and relief from appellate authorities.

Salary for international assignment subjected to tax in UK is not taxable in India

October 3, 2024 474 Views 0 comment Print

ITAT Chennai held that salary received for international assignment which is subjected to tax in UK could not be taxed in India. Accordingly, claim of the assessee allowed. The assessee being non-resident individual filed return of income declaring income of Rs.2295/- and claiming refund of Rs.10.08 Lacs.

Final assessment order set aside as passed before disposal of rectification application: Karnataka HC

October 1, 2024 309 Views 0 comment Print

Karnataka High Court held that since rectification application was filed before passing of final assessment order, DRP ought to have waited till disposal of rectification application. Thus, final assessment order liable to be set aside.

Cloud Subscription Fees Not Royalty under India-Ireland DTAA: ITAT Delhi

September 30, 2024 459 Views 0 comment Print

ITAT Delhi rules that subscription fees from cloud services are not taxable as royalty under the India-Ireland DTAA. 

Damages is capital receipt but interest on damages is revenue receipt: ITAT Delhi

September 24, 2024 591 Views 0 comment Print

ITAT Delhi held that damages are compensation received is a capital receipt, however, interest on damages is to be treated as revenue receipt hence the same is taxable.

Amount Received from US Broadcasting Company Not Taxable as “Royalty” Under India-US DTAA

September 24, 2024 393 Views 0 comment Print

Distribution revenue received by Turner Broadcasting System Asia Pacific, Inc. ( TBSAP ), a U.S.-based company, from its Indian affiliate was not taxable as “royalty” under the Income Tax Act, 1961, or the India-U.S.

Matter remanded as TP adjustment could not be at ‘NIL’ as determined by TPO

September 23, 2024 408 Views 0 comment Print

Assessee claimed to have receiving services in the fields of technology, Services, Risk Information Management, Head quarter, Technology Services/back office support services/treasury/regional headquarter services etc.

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