Trading and Support Go Hand-in-Hand: ITAT Rules in Favour of Juniper India: Transfer Pricing dispute
Trading and Support Go Hand-in-Hand: ITAT Rules in Favour of Juniper India: Transfer Pricing dispute In a recent ruling that underscores the importance of substance over form in transfer pricing, the Delhi Bench of the Income Tax Appellate Tribunal (ITAT) quashed a transfer pricing adjustment made against Juniper Networks Solution India Pvt Ltd for… […]
No TP Adjustment on Brand Royalty: ITAT Follows Precedent in Vodafone Case
No TP Adjustment on Brand Royalty: ITAT Follows Precedent in Vodafone Case The Delhi Bench of the Income Tax Appellate Tribunal (ITAT) has set aside a ₹120.54 crore transfer pricing (TP) adjustment related to brand royalty payments made by Vodafone Idea Ltd for Assessment Year (AY) 2012-13. The ruling in Vodafone Idea Ltd vs… […]
Key Restrictions on Cash Transactions under the Income-tax Act, 1961
Key Restrictions on Cash Transactions under the Income-tax Act, 1961 1. Section 40A(3) – Disallowance of Cash Expenditure Any business expenditure paid in cash exceeding ₹10,000 (₹35,000 for payments to transporters) to a person in a day is disallowed. If an expense allowed earlier is later paid in cash, it becomes income under Section… […]
ITR Date Extension: The Great Indian Waiting Game
ITR Date Extension: The Great Indian Waiting Game It’s that time of the year again — when coffee turns into our primary source of nutrition, Excel sheets are our best friends, and the entire country collectively asks one question: “Will the ITR date be extended or not?” For taxpayers and professionals alike, this has become… […]
Bareboat Charter Payments to AE Held at Arm’s Length When Key Functions and Risks Lie with Indian JV
Bareboat Charter Payments to AE Held at Arm’s Length When Key Functions and Risks Lie with Indian JV Mumbai ITAT deletes TP adjustment on bare‑boat charter hire in SP Armada Oil Exploration for AY 2021‑22 Introduction: In the case of SP Armada Oil Exploration Private Limited v. Deputy Commissioner of Income Tax – Circle 3(3)(1), Mumbai (ITA No. 6575/Mum/2024 for AY 2021‑22), the… […]
Failure to Grant Cross-Examination in Bogus Purchase Cases – Bombay High Court Upholds Relief, Restricts Addition to 15%
Failure to Grant Cross-Examination in Bogus Purchase Cases – Bombay High Court Upholds Relief, Restricts Addition to 15% Pr. CIT v. Ramelex Pvt. Ltd. (ITA No. 14/2022) Facts: 1. The assessee, Ramelex Pvt. Ltd., engaged in trading activities, was subjected to reassessment under Section 147 of the Income-tax Act. 2. Reopening was based on… […]
CBDT Empowers CIT (CPC), Bengaluru with Concurrent Powers for Rectification:
CBDT Empowers CIT (CPC), Bengaluru with Concurrent Powers for Rectification: Notification No. 155/2025 | Dated: October 27, 2025 Introduction: Issued under Sections 120(1) and 120(2) of the Income-tax Act, 1961, this Notification empowers the Commissioner of Income-tax, Centralized Processing Centre (CPC), Bengaluru, to exercise concurrent jurisdiction with other income-tax authorities. The CIT (CPC), Bengaluru… […]
Guide on TDS Compliance on payment to Non-Resident: All about TDS return filing after payment
Guide on TDS Compliance on payment to Non-Resident: All about TDS return filing after payment When TDS is deducted under Section 194 or Section 195 (which actually applies to payments to non-residents, such as fees for technical services, royalty, interest, or any other sum chargeable under the Act), the process of filing the TDS return is slightly different from… […]
Extension of time lines for filing of CRA -4 till Dec 31
Extension of time lines for filing of CRA -4 till Dec 31 The copy of the Circular is as under: The post Extension of time lines for filing of CRA -4 till Dec 31 appeared first on The Tax Talk.
Prosecution under Section 276C(2) Unsustainable When Entire Tax Paid Before Filing of Complaint
Prosecution under Section 276C(2) Unsustainable When Entire Tax Paid Before Filing of Complaint Madras High Court in G Square Layout Pvt. Ltd. v. DCIT (Crl.O.P.No.22880 of 2025) Facts: 1. The assessed filed its belated return for AY 2023-24 on 31st December 2023, admitting self-assessment tax of ₹ 8.72 crore but did not pay it… […]
