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...
ITAT remanded the matter where the assessee claimed PAN misuse leading to additions under Sections 68 and 69. It directed AO to verify the police report, holding that relief must be granted if misuse is substantiated.
ITAT Kolkata held that professional fees for works related to acquisition of new unit or expansion of existing undertaking is governed by provisions of section 35D of the Income Tax Act. Thus, since there is a specific provision u/s. 35D for amortization of certain preliminary expenses, the recourse could not have been had to the residuary provision of section 37(1) of the Act.
The Tribunal held that the TPO failed to consider the assessee’s Internal CUP benchmarking despite directions from the DRP. It directed fresh examination using the correct method and excluded certain NCDs from adjustment.
The ITAT held that provision for dealer incentives under a sales promotion scheme was based on a scientific method and not a contingent liability. The disallowance made by the tax authorities was therefore deleted.
ITAT Delhi held that while selecting the comparables transactions or entities, in case of international transactions, the basis should be one of similarity with the control transactions/entities and mere broad similarity is not sufficient.
The Tribunal ruled that an assessment order passed after DRP directions is still subject to revision under Section 263. It held that there is no statutory bar preventing the Principal Commissioner from revising such orders.
The tribunal examined whether the reasons given for late filing of the appeal were sufficient. It ruled that routine administrative workload and grievance handling cannot explain a substantial delay.
ITAT Delhi held that Oracle India Private Limited is an independent legal entity and existence of Oracle India Private Limited cannot be considered as permanent establishment of Oracle Systems Corporation. Hence, there is not question of attribution of profit to Permanent Establishment.
The ITAT held that when non-jurisdictional High Courts give conflicting decisions, a division bench ruling should be preferred over a single judge decision. On that basis, the Tribunal rejected the assessee’s claim that the assessment order was time-barred.
The Tribunal removed the transfer pricing addition on delayed receivables from associated enterprises, holding that the company’s profit margins exceeded comparable companies and interest was already embedded in pricing.
