Income Tax : The Tribunal ruled that non-specification of the precise statutory charge under sections 270A(2) and 270A(9) violated principles o...
Income Tax : Budget 2026 proposes allowing taxpayers to file an updated return even after receiving a reassessment notice under Section 148. Wh...
Income Tax : Misreporting under Section 270A(9) applies only to six specific circumstances. Where the assessment order does not clearly establi...
Income Tax : The law now proposes a single consolidated assessment-cum-penalty order for under-reporting of income, reducing multiple proceedin...
Income Tax : Detailed overview of penalties under various sections of the Income Tax Act, covering defaults in tax payment, reporting, document...
Income Tax : Explore amendments to section 253 of Income-tax Act, adjusting time limits for filing appeals to the Income Tax Appellate Tribunal...
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 Delhi ITAT held that penalty proceedings under Section 270A are invalid when the Assessing Officer does not identify the preci...
Income Tax : The Tribunal ruled that the use of the word may in Section 271AAC gives discretionary power to the Assessing Officer and does not ...
Income Tax : The Tribunal held that mere disallowance of deduction claimed under Section 80GGC does not automatically amount to misreporting of...
Income Tax : The Tribunal held that once the income disclosed in the return filed under Section 148 was accepted without any addition, there co...
The ITAT observed that mere remote access to customer-owned systems does not satisfy the disposal and permanence tests required for constituting a Fixed Place PE under the India-Canada DTAA.
The Delhi ITAT held that penalty proceedings under Section 270A are invalid when the Assessing Officer does not identify the precise statutory clause for under-reporting or misreporting of income. The Tribunal ruled that such omission goes to the root of jurisdiction.
The Tribunal ruled that the use of the word may in Section 271AAC gives discretionary power to the Assessing Officer and does not mandate automatic penalty levy. It emphasized that such discretion must be exercised judiciously.
The Tribunal held that mere disallowance of deduction claimed under Section 80GGC does not automatically amount to misreporting of income. It deleted the penalty as there was no evidence of false particulars or fabricated documents.
The Tribunal held that once the income disclosed in the return filed under Section 148 was accepted without any addition, there could be no allegation of under-reporting or misreporting. The entire penalty of ₹4.91 lakh was deleted.
ITAT Ahmedabad held that no unexplained investment addition could survive where the booked property deal was cancelled and funds were refunded. The ruling emphasized verification of actual payment flow and subsequent cancellation events.
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-generating intra-group service. The Tribunal deleted the transfer pricing adjustment after finding the benchmarking method adopted by the TPO unjustified.
The Bombay High Court held that reassessment proceedings issued beyond three years for AY 2018-19 were invalid because approval was granted by the Principal Commissioner instead of the competent authority under Section 151(ii).
Transfer Pricing Officer (TPO) had wrongly recharacterised Boeing India Defense Private Limited as a full-risk service provider despite the Associated Enterprise (AE) assuming the entire contractual and operational risks relating to defence support services rendered to the Indian Air Force (IAF).
The Tribunal upheld disallowance of deduction under Section 80GGC after finding the political donation lacked genuineness. The ruling highlights that payments through banking channels alone cannot establish a valid deduction when surrounding facts indicate accommodation entries.
