Judgement

ITAT held funtionally different company not comparable to a battery manufacturer; excise exemption claim remanded.

ITAT: Functionally Different Company Cannot Be Treated Comparable In Transfer Pricing

News

The IT Dept has detected large-scale sales suppression in the restaurant sector and launched the Saksham NUDGE campaign, urging 63,000 restaurants to update their tax returns before March 31, 2026.

CBDT Urges 63,000 Restaurants to Update Returns Before March 31 under ‘Saksham NUDGE’ Campaign

This "reverse flip" is advantageous for companies like Flipkart to better align with Indian regulations, increase their valuation, and signal trust in the domestic market.

Flipkart Relocates Domicile to India to Align with Local Regulations and IPO Plans

ITAT held that where the AO accepted a registered valuer’s FMV after examination, the order cannot be revised under Section 263 merely because the PCIT believes a DVO reference should have been made.

Tribunal Sets Aside Section 263 Revision, Where AO Examined Valuation

The Tribunal held that sale of off-the-shelf software to Indian distributors did not create a dependent agent PE; income not taxable in India.

ITAT: Loan Write Off To Subsidiary Disallowed For Lack Of Commercial Prudence

ITAT held that sale of off-the-shelf software by Milestone Systems A/S to Indian distributors did not create a Dependent Agent PE under the India–Denmark DTAA, making the income non-taxable in India.

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ITAT: Functionally Different Company Cannot Be Treated Comparable In Transfer Pricing

CBDT Urges 63,000 Restaurants to Update Returns Before March 31 under ‘Saksham NUDGE’ Campaign

Flipkart Relocates Domicile to India to Align with Local Regulations and IPO Plans

Tribunal Sets Aside Section 263 Revision, Where AO Examined Valuation

ITAT: Loan Write Off To Subsidiary Disallowed For Lack Of Commercial Prudence

ITAT Says Software Licence Sales Not Taxable In Absence Of Permanent Establishment