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 : The ITAT observed that mere remote access to customer-owned systems does not satisfy the disposal and permanence tests required fo...
Income Tax : The ITAT Delhi ruled that reimbursement of software costs to foreign AEs on a cost-to-cost basis could not be treated as a profit-...
Income Tax : Tribunal found the DRP’s order cryptic and lacking proper analysis on similarity of business activities between the assessee and...
Income Tax : The Tribunal ruled that margins agreed under a Bilateral Advance Pricing Agreement may be used for non-covered AEs when transactio...
Income Tax : Delhi ITAT directed exclusion of a comparable company engaged in video conferencing solutions after noting that the DRP had alread...
ITAT Mumbai held that provisions of section 56(2)(x) of the Income Tax Act have no applicability on conversion of Optionally Convertible Cumulative Redeemable Preference Shares into equity shares. Accordingly, addition made by invoking section 56(2)(x) cannot be sustained. Thus, appeal is allowed.
ITAT Mumbai held that disallowance made under section 14A of the Income Tax Act added to Book Profits for computing taxes under section 115JB Income Tax Act deserved to be deleted.
The authorities compared intra-group commission rates without economic analysis. The Tribunal ruled that such an approach leads to invalid transfer pricing adjustments.
ITAT Bangalore held that at the relevant time co-founder of Flipkart stayed in India for 141 days and balance days in other countries. Hence, assessee is an Indian national and thus the appeal of the assessee is dismissed.
The Tribunal held that section 56(2)(vii)(b) applies automatically when stamp value exceeds purchase price. However, it remanded the matter for DVO valuation to ensure fair determination of market value.
While following binding High Court precedent on limitation, the Tribunal quashed the assessment order. Liberty was granted to revive the matter depending on the Supreme Court’s final decision.
The Tribunal found that the assessee was not questioned on stamp duty valuation and old payment sources. It remanded the case for fresh assessment with directions to consider explanations afresh.
The tribunal examined whether a final assessment passed after the statutory time limit was valid. It held that assessments beyond Section 153 timelines are void, even when issued under the DRP framework.
The issue was whether a final assessment under the DRP framework can be passed beyond statutory timelines. The Tribunal held that orders exceeding Section 153 limits are void, reaffirming strict adherence to limitation.
ITAT Delhi held that final assessment order passed beyond the period of limitation for passing the order u/s 144C(13) r.w.s. 153 of the Income Tax Act. Accordingly, the same is barred by limitation and hence liable to be quashed.
