Income Tax : This guide explains when penalties can be imposed under various provisions of the Income-tax Act, 1961. It also outlines the appli...
Income Tax : ITAT Mumbai held that penalty under Section 270A cannot be levied merely because income was estimated after rejection of books. Si...
Income Tax : The article explains how transactions between associated domestic entities exceeding ₹20 crore must comply with arm's length pri...
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 : Explore amendments to section 253 of Income-tax Act, adjusting time limits for filing appeals to the Income Tax Appellate Tribunal...
Income Tax : ITAT Delhi held that IT, salary and travel reimbursements without any profit element were not taxable and deleted the disallowance...
Income Tax : ITAT held that an Assessing Officer cannot substitute the DCF method chosen under Rule 11UA with the NAV method without legal just...
Income Tax : ITAT held ₹33 crore settled rights over the entire land, allowing full indexed acquisition cost and rejecting proportionate rest...
Income Tax : ITAT excluded EDCIL, Just Dial, Info Edge and India Exposition Mart as transfer pricing comparables due to functional differences ...
Income Tax : The Tribunal ruled that a penalty notice lacking a specific allegation of under-reporting, misreporting, or the applicable clause ...
The Kerala High Court held that Section 144B does not require issuance of a draft assessment order to an ordinary assessee. It ruled that the requirement applies only to an eligible assessee as defined under the Income Tax Act.
The ITAT Hyderabad held that certified segmental financial information could not be rejected mechanically without identifying defects. It remanded the issue to the TPO for fresh consideration.
The ITAT Mumbai held that penalty under Section 270A cannot be sustained where the show cause notice and assessment order fail to specify whether the allegation is under-reporting or misreporting of income. The Tribunal upheld deletion of the penalty after finding the notice lacked a definite charge.
The ITAT observed that registration undertaken solely to satisfy a banks mortgage requirement cannot automatically attract tax under Section 56(2)(x). It restored the matter for fresh examination of the true nature of the transaction.
ITAT Delhi held that an assessment framed after an approved merger in the name of the amalgamating company was without jurisdiction. The assessment order and DRP directions were set aside because the company had ceased to exist.
The ITAT Delhi held that the Transfer Pricing Officer could not arbitrarily determine the arm’s length price of management services at nil despite evidence establishing receipt of services. The Tribunal restored the assessees TNMM-based benchmarking by following its earlier decision.
ITAT Ahmedabad held that the Transactional Net Margin Method (TNMM) remained the most appropriate method as there was no change in the assessee’s functional profile and earlier Tribunal decisions had consistently accepted it. The transfer pricing adjustment based on the internal Cost Plus Method was deleted.
The ITAT Mumbai held that Section 69C cannot be invoked where expenditure is duly recorded in the books and its source is fully explained. It deleted the addition relating to royalty, commission, and technical service payments.
The ITAT held that penalty under Section 270A could not be sustained because the Assessing Officer failed to clearly distinguish between under-reporting and misreporting of income. The penalty was deleted for lack of a specific finding.
The Delhi High Court held that immunity under Section 270AA could not be denied when the penalty notice did not specify whether the proceedings were for under-reporting or misreporting of income. The impugned order was set aside.
