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    Advance pricing agreement guidance curbs excessive royalty and technical fee transfer pricing adjustment in comparable transactions
    Reassessment jurisdiction upheld and notice service deemed under section 292BB after participation in proceedings despite prior scrutiny issue
    Stamp duty value addition fails where earlier agreement and prior cheque payments fix the purchase consideration.
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    Foreign tax credit cannot be denied for belated Form 67 filing; delay is only a procedural lapse.
    Turnover filter and receivables benchmarking in transfer pricing led to exclusion of comparables, remand, and recomputation.
    Allotment Date Determines Holding Period for Long-Term Capital Gain; Additional Evidence Treated as Admitted in Appeal
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      Extra Duty Deposit in related-party provisional assessment...

      Refund interest on extra duty deposit accrues after three months when finalised provisional assessments leave no duty due.

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      CustomsJune 18, 2026Case LawsAT
      Extra Duty Deposit in related-party provisional assessment proceedings is refundable once final valuation shows no further duty payable, because the deposit is not customs duty and does not survive as a deficiency payment. On delayed refund, the Section 27A interest principle applies mutatis mutandis: interest runs from expiry of three months after the refund entitlement arises until actual payment, even if the amount had earlier been credited to the Consumer Welfare Fund on unjust enrichment grounds. The denial of interest was set aside and refund interest was held payable.

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      ActsIncome Tax