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 assessing authority made a large addition without explaining its nature or legal basis. The Tribunal ruled that such a cryptic order cannot stand and set aside the addition.
The Tribunal observed that the transfer pricing adjustment was based on unexplained margin calculations. A fresh working was directed to ensure accurate benchmarking of international transactions.
Additions were made solely because the trust failed to submit details during assessment and appeal. ITAT set aside the assessments for fresh adjudication, stressing that substantive claims should be decided on merits rather than procedural lapses.
The High Court held that issuing a draft assessment order under Section 144C is invalid where the Transfer Pricing Officer proposes no variation. The key takeaway is that absence of TP adjustment means the assessee is not an “eligible assessee,” making DRP proceedings without jurisdiction.
ITAT Delhi held that foreign company receiving consideration for offshore supply of equipment, plant, designs and drawings is not taxable in India since entire transaction has taken place outside India.
The Tribunal held that merely treating a claimed business loss as a speculative loss amounts to a change in head of loss, not under-reporting of income. Penalty under Section 270A was deleted as there was no concealment or furnishing of inaccurate particulars.
High Court held that a final assessment order passed without awaiting DRP directions violates section 144C. Such non-compliance rendered the assessment order non est and liable to be quashed.
Where the CIT(A) rejected the appeal only on limitation, the Tribunal intervened. It directed fresh adjudication of the penalty after condoning the 380-day delay.
The Tribunal held that additional evidence accepted by the appellate authority must be examined by the Assessing Officer. Allowance based only on banking payments and charitable status was found inadequate.
The issue was whether interest-free loans to group entities warranted transfer pricing adjustment. The Tribunal held that since business had not commenced and no income was earned, the adjustment was unsustainable.
