Tag Archives: ACIT

ITAT Rules Indian PE Interest Income, Shared Hub Costs, and MTM Losses Non-Taxable or Deductible

By | August 1, 2026
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ITAT Rules Indian PE Interest Income, Shared Hub Costs, and MTM Losses Non-Taxable or Deductible ITAT Rules Indian PE Interest Income, Shared Hub Costs, and MTM Losses Non-Taxable or Deductible Issue Whether interest credited by Head Office, shared regional hub expenses, broken period interest, expatriate salary reimbursements, year-end Mark-to-Market (MTM) losses on forex contracts, and… Read More »

Broader Auto-Component Manufacturer Is Valid TNMM Comparable and Loss Set-Off Must Be Granted

By | July 30, 2026
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Broader Auto-Component Manufacturer Is Valid TNMM Comparable and Loss Set-Off Must Be Granted Broader Auto-Component Manufacturer Is Valid TNMM Comparable and Loss Set-Off Must Be Granted Issue Whether a company performing broader auto-component manufacturing functions can be accepted as a valid comparable under the Transactional Net Margin Method (TNMM), particularly when accepted by the Transfer… Read More »

Interest from Head Office, Hub Costs, Broken-Period Interest, Salary Reimbursements, MTM Losses, and Securities Diminution Are Allowable

By | July 30, 2026
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Interest from Head Office, Hub Costs, Broken-Period Interest, Salary Reimbursements, MTM Losses, and Securities Diminution Are Allowable Issue Whether interest credited to an Indian Permanent Establishment (PE) branch by its foreign Head Office/overseas branches is taxable in India under Section 9 read with Article 7 of the India-USA DTAA. Whether centralized operational hub expenses paid… Read More »

Company Performing Broader Auto-Component Manufacturing Functions Is a Valid Transfer Pricing Comparable Under TNMM

By | July 30, 2026
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Company Performing Broader Auto-Component Manufacturing Functions Is a Valid Transfer Pricing Comparable Under TNMM Issue Whether a company performing broader auto-component manufacturing functions can be selected as a valid comparable under the Transactional Net Margin Method (TNMM), especially when accepted in subsequent assessment years. Whether the Assessing Officer (AO) is required to grant set-off of… Read More »

Consolidated Satisfaction Note Covering Multiple Years Invalidates Section 153C Assessment Proceedings

By | July 25, 2026
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Consolidated Satisfaction Note Covering Multiple Years Invalidates Section 153C Assessment Proceedings Issue Validity of Section 153C Assessment Proceedings Based on a Consolidated Satisfaction Note: Whether the initiation of proceedings and subsequent additions made under Section 69A (read with Section 153C) are legally valid when the Assessing Officer records a single, common satisfaction note covering multiple… Read More »

Estimated Addition On Suppressed Professional Receipts Based On Third-Party Statements Without Account Rejection Is Unsustainable

By | July 25, 2026
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Estimated Addition On Suppressed Professional Receipts Based On Third-Party Statements Without Account Rejection Is Unsustainable Issue Validity of Reassessment Addition Based on Estimation: Whether an addition made on account of alleged suppression of professional receipts—calculated purely on estimated hospital consultation charges and manager statements without rejecting the assessee’s books of account or bringing independent corroborative… Read More »

In the interest of justice, foreign bank unexplained cash credit addition is remanded for fresh consideration.

By | July 24, 2026
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In the interest of justice, foreign bank unexplained cash credit addition is remanded for fresh consideration. In the interest of justice, foreign bank unexplained cash credit addition is remanded for fresh consideration. Issue Whether the addition made under Section 68 of the Income-tax Act, 1961 towards unexplained credits in a foreign bank account should be… Read More »

Tribunal Upholds Major Transfer Pricing, Business Loss, and Tax Deductions for Assessee Steel Manufacturer

By | July 23, 2026
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Tribunal Upholds Major Transfer Pricing, Business Loss, and Tax Deductions for Assessee Steel Manufacturer Tribunal Upholds Major Transfer Pricing, Business Loss, and Tax Deductions for Assessee Steel Manufacturer Issue Whether transfer pricing adjustments on AE loans/guarantees/captive power, deductions for bad debts/business losses/written-off capital liabilities, sales tax gains, and Section 14A/115JB adjustments were rightly decided in… Read More »

Assessment under the Black Money Act is void for a Resident Not Ordinarily Resident as foreign shares acquired out of non-taxable foreign income are non-assessable and incorrectly valued.

By | July 23, 2026
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Assessment under the Black Money Act is void for a Resident Not Ordinarily Resident as foreign shares acquired out of non-taxable foreign income are non-assessable and incorrectly valued. Assessment under the Black Money Act is void for a Resident Not Ordinarily Resident as foreign shares acquired out of non-taxable foreign income are non-assessable and incorrectly… Read More »

Section 80-IA Deduction Capped at Gross Total Income, PF Interest Allowable, and Section 14A Inapplicable Without Exempt Income

By | July 22, 2026
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Section 80-IA Deduction Capped at Gross Total Income, PF Interest Allowable, and Section 14A Inapplicable Without Exempt Income Issue Section 80-IA Capping: Whether deduction under Section 80-IA can be set off against the Gross Total Income (including Capital Gains) up to the limit prescribed under Section 80A(2), or if it must be restricted solely to… Read More »