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I-T - Time limit prescribed for AO to pass assessment u/s 144C(13), shall be reckoned from date of original directions issued by DRP u/s 144C(5), and not from subsequent corrigendum to directions issued by DRP: ITAT (See Breaking News)

TP - Considerations which apply for issuance of Corporate Guarantee to AES are distinct from that of Guarantee provided by banks: ITAT (See Breaking News)

I-T - Capital gain earned by non-resident assessee upon sale of shares /derivatives acquired prior to April 01, 2017 cannot be subjected tax in India: ITAT (See Breaking News)

TP - Aggregation transaction approach can be adopted only where, there exists close inter-linking between all transactions: ITAT (See Breaking News)

I-T- Deduction u/s 35D pertaining to expenses incurred before commencement of business, rightly disallowed where assessee fails to provide adequate documentation: ITAT (See Breaking News)

I-T- Draft assessment order is invalid where it passed beyond the period of one month from receipt of directions from DRP: ITAT (See Breaking News)

I-T - Assistance provided with respect to rules and regulations for clearance of customs frontiers, is not 'specialised knowledge' to render such service as 'FTS': HC (See Breaking News)

TP - Period of Sec 144C(13) can't be counted from end of month in which transfer pricing officer gives effect of direction of DRP u/s 144C(5): HC (See Breaking News)

I-T - Consideration paid for purchase of software, cloud computing, cloud space hiring involving transfer of right to use software, is not royalty: HC (See Breaking News)

I-T - Only because Tribunal has not dealt with merits of matter, same cannot be considered as information, so as to assume jurisdiction to issue reopening notice u/s 148: HC (See Breaking News)

TP - Market value of power supplied by State Electricity Board to industrial consumers should be construed to be market value of electricity: ITAT (See Breaking News)

I-T - Extended time of 12 months in terms of section 153(4) is available only in case, where reference u/s 92CA is made to TPO, but not in case of assessment of non-resident u/s 148 r.w.s. 144C: ITAT (See Breaking News)

INTL - Penalty u/s 271(1)(c) not tenable where change in assessee's status in relevant period from resident to non-resident, being debatable in nature, led to changed pattern of ITR filing: ITAT (See Breaking News)

Of Budget 2025 & Non-Resident Taxation (See TII Edit)

TP - TPO can't compute ALP of assessee's international transactions as nil, merely because despite services availed from such transactions, assessee incurred loss in business: HC (See Breaking News)

I-T - Assessee having no PE in India, in terms of Article 5 of India-Singapore tax treaty, washout receipts, being in nature of business income would not be taxable in India: ITAT (See Breaking News)

I-T - Once capital gains are considered as exempt under tax treaty, there would not be any occasion for seeking adjustment of brought forward short-term capital loss against such exempt capital gains: ITAT (See Breaking News)

I-T - Challenge to reopening notice issued u/s 148 can't be countenanced merely because due to typographical error in address, notice was not served to assessee's correct address: HC (See Breaking News)

I-T - If Indian subsidiary is not dependent agent PE, then no further attribution of profit can be made if said subsidiary was remunerated at arm's length: HC (See Breaking News)

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