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 issue was addition of cash deposits during demonetisation as unexplained income. The Tribunal held that the assessee’s explanation supported by affidavit was credible, leading to deletion of the addition.
The Tribunal held that an assessment order passed in compliance with DRP directions cannot be revised under Section 263. It clarified that such orders are not erroneous as the Assessing Officer is bound by DRP’s binding instructions.
Tribunal held that technical handling income is covered under Article 8 of India–France DTAA. It ruled that such income arises from operation of aircraft in international traffic and is not taxable in India.
The Tribunal held that GST collected is not part of income for presumptive taxation under section 44B. It ruled that GST is a statutory levy and cannot be treated as revenue.
The case addressed whether a demand based on a draft order can be enforced. The Court held that tax liability crystallizes only after final assessment. Key takeaway: draft orders have no enforceable value.
The ITAT held that issuing a demand notice and penalty along with a draft order makes it a final order. Non-compliance with Section 144C rendered the assessment invalid.
The Tribunal held that transfer pricing adjustment cannot survive without a final assessment order post-DRP directions. Repeating such addition in a Section 263 order was held invalid.
The Tribunal held that subscription to preference shares cannot be re-characterized as loans in absence of evidence showing sham transactions. Notional interest addition was deleted.
The case involved reopening of assessment based on issues already examined during scrutiny. The Court held that reassessment without new material is invalid. It ruled that reopening on the same facts amounts to impermissible action.
The Court held that an assessment order passed in the name of an amalgamating, non-existent entity is void. It ruled that system glitches cannot cure a fundamental jurisdictional defect.
