#Section 144C
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543 articlesIncome Tax

Income Tax
Management Support Fees Not FTS Without ‘Make Available’ Under Article 12(4): ITAT Mumbai
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Section 143(2) Notice & Valid Draft Assessment Mandatory U/s 144C: ITAT Mumbai
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Amalgamation Goodwill Eligible for Depreciation; Notional Interest on AE Receivables Deleted: ITAT Delhi
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Captive Service Provider Entitled to Risk Adjustment; Nil ALP for Proven Intra-Group Services Rejected: ITAT Delhi
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ITAT Delhi Excludes TPO Comparables for Functional Dissimilarity
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ITAT Deletes Brand Promotion TP Adjustment as Issue Was Already Settled in Earlier Years
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Section 68 Addition Deleted as Assessee Proved Identity, Creditworthiness & Genuineness
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ITAT Quashes Assessment as Final Order Was Passed Beyond Section 144C(13) Time Limit
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Delhi HC Dismisses Assessment Passed Beyond Section 144C Time Limit
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ITAT Excludes Incomparable Companies as Functional Differences & Turnover Distorted TP Analysis
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No Separate Approval Needed for 10% FTS Tax Benefit Where RBI Automatic Route Applies
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ITAT Bangalore Deletes Additions as AO Issued Second Draft Assessment Order
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TP Adjustment Set Aside for Failure to Prove Profit Shifting Under Section 80-IA(10)
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