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...
The Tribunal examined whether donations made as part of CSR obligations could qualify for deduction under Section 80G. It held that deduction cannot be denied merely because the payment was made towards CSR, subject to fulfillment of Section 80G conditions.
The ITAT held that transfer pricing adjustment was not justified where the foreign LLC’s income was already offered to tax in India by the assessee. The Tribunal deleted the TP addition, finding no profit shifting or tax erosion.
The High Court held that the statutory requirement of issuing a draft assessment order could not be bypassed by issuing a final order accompanied by tax demand and penalty proceedings.
The ITAT held that a transfer of jurisdiction under Section 127(2) is invalid if the assessee is not given a reasonable opportunity of being heard. As a result, notices issued by the transferee officers lacked legal validity and the assessment was quashed.
The final assessment order was emailed to the assessee after the limitation period had expired. The Tribunal held that the delayed communication rendered the assessment time-barred.
Where ITAT directed inclusion of Cepha Imaging Pvt. Ltd. as a comparable solely on the basis that it satisfied the export turnover filter without examining its functional comparability with assessee, and further directed inclusion of CG Vak Software & Exports Ltd.
The High Court held that the addition under Section 40(a)(i) could not survive because it was made contrary to the DRP’s binding directions. The assessment order was set aside to that extent.
The ITAT Bangalore held that disallowance under Section 40(a)(i) could not survive once the recipient of the income settled the tax dispute under the Vivad se Vishwas Scheme, 2024. The ruling relied on CBDT Circular No.19/2024 and FAQ No.58 granting consequential relief to the deductor.
The Tribunal restored issues relating to comparable company margins and working capital adjustment after finding that the assessee’s submissions required verification. The appeal was allowed for statistical purposes.
ITAT Delhi deleted transfer pricing adjustments after holding that retail and after-sales businesses could not be compared with wholesale trading to OEMs. The Tribunal ruled that comparables must satisfy functional and market similarity under Rule 10B(2).
