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    August 5, 2026   Case LawsGST
    Deemed withdrawal of best-judgment assessment follows timely valid return filing, while late fee and interest liabilities continue.
    August 5, 2026   Case LawsGST
    Interest and penalty on delayed GST payment remain stayed pending verification of payment through input tax credit adjustment.
    August 5, 2026   Case LawsIncome Tax
    Inherent quashing jurisdiction cannot decide disputed defences on non-supply of seized material or wilful failure to file returns.
    August 5, 2026   Case LawsIncome Tax
    Eligible industrial deductions and book-profit adjustments turn on income nexus, exempt-fund presumption, valuation, and lawful appellate claims.
    August 5, 2026   Case LawsIncome Tax
    Website development depreciation, banking gateway fees, and revenue advertising expenses receive favourable treatment under discussed tax principles.
    August 5, 2026   Case LawsIncome Tax
    Foreign-currency loan benchmarking follows the loan currency, while export hedging losses qualify as non-speculative business losses.
    August 5, 2026   Case LawsIncome Tax
    Delayed initiation of TDS return penalties after nine years rendered the penalty illegal and unsustainable.
    August 5, 2026   Case LawsIncome Tax
    Project-development assistance treated as capital, while infrastructure construction costs may be amortised over the concession period.
    August 5, 2026   Case LawsIncome Tax
    Delayed trade receivables require separate transfer pricing benchmarking, subject to debt-free status and an appropriate credit period.
    August 5, 2026   Case LawsIncome Tax
    Modified returns, MAT book profit limits, and tested-party selection shape transfer pricing treatment of integrated intra-group services.
    August 5, 2026   Case LawsIncome Tax
    Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
    August 5, 2026   Case LawsIncome Tax
    Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
    August 5, 2026   Case LawsIncome Tax
    Share valuation method choice protects DCF valuations from replacement with NAV, though projections remain open to scrutiny.
    August 5, 2026   Case LawsIncome Tax
    Penalty immunity requires reconsideration where rectification removes the assessment demand and leaves a refund instead.
    August 5, 2026   Case LawsIncome Tax
    Under-reporting penalty applies when taxable income is not returned, even if reassessment disclosure is accepted without additions.
    August 5, 2026   Case LawsBenami Property
    Benami RTGS credits unsupported by independent evidence justified attachment, while unproven prejudice defeated the natural justice challenge.
    August 5, 2026   Case LawsCustoms
    Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
    August 5, 2026   Case LawsCustoms
    Brand rate drawback for bus bodies may coexist with DEPB where duplicate duty reimbursement is not established by evidence.
    August 5, 2026   Case LawsCustoms
    Made-up textile article classification governs triangular umbrella panels, while full customs disclosure prevents extended limitation in classificatio...
    August 5, 2026   Case LawsCustoms
    Abetment penalties require proof that a Customs Broker representative knowingly facilitated improper importation of prohibited goods.
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    August 5, 2026   Case Laws GST
    Deemed withdrawal of best-judgment assessment follows timely valid return filing, while late fee and interest liabilities continue.
    August 5, 2026   Case Laws GST
    Interest and penalty on delayed GST payment remain stayed pending verification of payment through input tax credit adjustment.
    August 5, 2026   Case Laws Income Tax
    Inherent quashing jurisdiction cannot decide disputed defences on non-supply of seized material or wilful failure to file returns.
    August 5, 2026   Case Laws Income Tax
    Eligible industrial deductions and book-profit adjustments turn on income nexus, exempt-fund presumption, valuation, and lawful appellate claims.
    August 5, 2026   Case Laws Income Tax
    Website development depreciation, banking gateway fees, and revenue advertising expenses receive favourable treatment under discussed tax principles.
    August 5, 2026   Case Laws Income Tax
    Foreign-currency loan benchmarking follows the loan currency, while export hedging losses qualify as non-speculative business losses.
    August 5, 2026   Case Laws Income Tax
    Delayed initiation of TDS return penalties after nine years rendered the penalty illegal and unsustainable.
    August 5, 2026   Case Laws Income Tax
    Project-development assistance treated as capital, while infrastructure construction costs may be amortised over the concession period.
    August 5, 2026   Case Laws Income Tax
    Delayed trade receivables require separate transfer pricing benchmarking, subject to debt-free status and an appropriate credit period.
    August 5, 2026   Case Laws Income Tax
    Modified returns, MAT book profit limits, and tested-party selection shape transfer pricing treatment of integrated intra-group services.
    August 5, 2026   Case Laws Income Tax
    Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustments.
    August 5, 2026   Case Laws Income Tax
    Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments cannot survive statutory omission.
    August 5, 2026   Case Laws Income Tax
    Share valuation method choice protects DCF valuations from replacement with NAV, though projections remain open to scrutiny.
    August 5, 2026   Case Laws Income Tax
    Penalty immunity requires reconsideration where rectification removes the assessment demand and leaves a refund instead.
    August 5, 2026   Case Laws Income Tax
    Under-reporting penalty applies when taxable income is not returned, even if reassessment disclosure is accepted without additions.
    August 5, 2026   Case Laws Benami Property
    Benami RTGS credits unsupported by independent evidence justified attachment, while unproven prejudice defeated the natural justice challenge.
    August 5, 2026   Case Laws Customs
    Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation right.
    August 5, 2026   Case Laws Customs
    Brand rate drawback for bus bodies may coexist with DEPB where duplicate duty reimbursement is not established by evidence.
    August 5, 2026   Case Laws Customs
    Made-up textile article classification governs triangular umbrella panels, while full customs disclosure prevents extended limitation in classification disputes.
    August 5, 2026   Case Laws Customs
    Abetment penalties require proof that a Customs Broker representative knowingly facilitated improper importation of prohibited goods.

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      Home› Highlights › Income Tax › 2026 › May, 2026 › This
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      Income Tax

      Turnover is a relevant comparability filter in transfer pricing...

      Turnover filter and functional comparability in software transfer pricing upheld; limited comparables can still support arm's length benchmarking.

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      Income TaxMay 29, 2026Case LawsAT
      Turnover is a relevant comparability filter in transfer pricing for software development services, and applying a ten-times range on both ends for selecting comparables was upheld. Several entities were excluded as functionally dissimilar because they were software product or diversified companies, or because earlier coordinate bench views supported exclusion and no contrary material was shown. Evoke Technologies Ltd. was retained as a comparable since audited records enabled identification of Indian operating revenue and computation of the profit level indicator after excluding overseas branch revenue. The Tribunal also held that benchmarking does not fail merely because only two comparables remain, and dismissed the Revenue's appeal.
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