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    March 5, 2026   Case Laws Central Excise
    Corroborative Evidence required: seizures and duty demands unsupported by input output theory were set aside for lack of positive proof.
    March 5, 2026   Case Laws VAT / Sales Tax
    Surcharge on tax leviable in addition to tax on declared goods when computed on tax payable.
    March 3, 2026   Case Laws GST
    Limitation period exclusion requires fresh adjudication of refund claims; administrative rejections cannot ignore the judicial exclusion.
    March 3, 2026   Case Laws GST
    Right to Personal Hearing: ineffective portal-only service requires alternate modes and fresh hearing before adjudication.
    March 3, 2026   Case Laws GST
    Effective service requirement: officers must explore alternative service modes beyond the GST portal and afford personal hearing; non-compliance voids...
    March 3, 2026   Case Laws Income Tax
    Cancelled transactions and reversal of consideration negate taxable income; assessments quashed where cancellation evidence was not considered.
    March 3, 2026   Case Laws Income Tax
    Invocation of Section 153C: reliance on external or public domain material or absence of AO satisfaction note invalidates proceedings.
    March 3, 2026   Case Laws Income Tax
    Computation of limitation for reopening: ten-year window reckoned from end of the relevant assessment year, notice quashed.
    March 3, 2026   Case Laws Income Tax
    Estimate-based additions do not satisfy proof-of-concealment required for penalty; penalty deleted where addition rests on estimate.
    March 3, 2026   Case Laws Income Tax
    Estimation of profit element in bogus purchases remitted for fresh adjudication to apply binding precedents and record reasons.
    March 3, 2026   Case Laws Income Tax
    Estimation of undisclosed income on turnover is unsustainable where banking evidence and books support transactions, so additions deleted.
    March 3, 2026   Case Laws Income Tax
    Limitation under Section 153(3) bars final assessments if DRP directions are issued after the prescribed statutory window.
    March 3, 2026   Case Laws Income Tax
    Permanent Establishment under DTAA not established, so off the shelf software receipts not taxable as royalty and presumptive tax inapplicable.
    March 3, 2026   Case Laws Income Tax
    Arm's length price: Internal CUP remand for NCD benchmarking; fresh deduction claim admitted and statutory interest on refund directed.
    March 3, 2026   Case Laws Income Tax
    Onus to Prove Genuineness of Share Transactions: documentary proof can rebut suspicion and protect 10(38) LTCG exemption.
    March 3, 2026   Case Laws Income Tax
    Admission of Additional Grounds affirmed where facts are on record; reopening quashed when additions do not flow from recorded reasons.
    March 3, 2026   Case Laws Income Tax
    Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
    March 3, 2026   Case Laws Income Tax
    Transfer Pricing: royalty adjustment negated by prior appellate precedent; typographical error did not defeat infrastructure deduction claim.
    March 3, 2026   Case Laws Income Tax
    Relevant date for Section 54 exemption: completion with payment and possession within two years qualifies for relief.
    March 3, 2026   Case Laws Customs
    Customs Valuation Rule sequence: Chartered Engineer certificate alone cannot justify rejection of transaction value; reassessment set aside.
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March 5, 2026   Case Laws Central Excise
Corroborative Evidence required: seizures and duty demands unsupported by input output theory were set aside for lack of positive proof.
March 5, 2026   Case Laws VAT / Sales Tax
Surcharge on tax leviable in addition to tax on declared goods when computed on tax payable.
March 3, 2026   Case Laws GST
Limitation period exclusion requires fresh adjudication of refund claims; administrative rejections cannot ignore the judicial exclusion.
March 3, 2026   Case Laws GST
Right to Personal Hearing: ineffective portal-only service requires alternate modes and fresh hearing before adjudication.
March 3, 2026   Case Laws GST
Effective service requirement: officers must explore alternative service modes beyond the GST portal and afford personal hearing; non-compliance voids orders.
March 3, 2026   Case Laws Income Tax
Cancelled transactions and reversal of consideration negate taxable income; assessments quashed where cancellation evidence was not considered.
March 3, 2026   Case Laws Income Tax
Invocation of Section 153C: reliance on external or public domain material or absence of AO satisfaction note invalidates proceedings.
March 3, 2026   Case Laws Income Tax
Computation of limitation for reopening: ten-year window reckoned from end of the relevant assessment year, notice quashed.
March 3, 2026   Case Laws Income Tax
Estimate-based additions do not satisfy proof-of-concealment required for penalty; penalty deleted where addition rests on estimate.
March 3, 2026   Case Laws Income Tax
Estimation of profit element in bogus purchases remitted for fresh adjudication to apply binding precedents and record reasons.
March 3, 2026   Case Laws Income Tax
Estimation of undisclosed income on turnover is unsustainable where banking evidence and books support transactions, so additions deleted.
March 3, 2026   Case Laws Income Tax
Limitation under Section 153(3) bars final assessments if DRP directions are issued after the prescribed statutory window.
March 3, 2026   Case Laws Income Tax
Permanent Establishment under DTAA not established, so off the shelf software receipts not taxable as royalty and presumptive tax inapplicable.
March 3, 2026   Case Laws Income Tax
Arm's length price: Internal CUP remand for NCD benchmarking; fresh deduction claim admitted and statutory interest on refund directed.
March 3, 2026   Case Laws Income Tax
Onus to Prove Genuineness of Share Transactions: documentary proof can rebut suspicion and protect 10(38) LTCG exemption.
March 3, 2026   Case Laws Income Tax
Admission of Additional Grounds affirmed where facts are on record; reopening quashed when additions do not flow from recorded reasons.
March 3, 2026   Case Laws Income Tax
Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing established.
March 3, 2026   Case Laws Income Tax
Transfer Pricing: royalty adjustment negated by prior appellate precedent; typographical error did not defeat infrastructure deduction claim.
March 3, 2026   Case Laws Income Tax
Relevant date for Section 54 exemption: completion with payment and possession within two years qualifies for relief.
March 3, 2026   Case Laws Customs
Customs Valuation Rule sequence: Chartered Engineer certificate alone cannot justify rejection of transaction value; reassessment set aside.

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Income Tax

Under section 144C(13), the limitation for passing the final...

Electronic receipt of DRP directions triggers limitation for final assessment, making a later order time-barred.

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Income Tax June 22, 2026 Case Laws AT
Under section 144C(13), the limitation for passing the final assessment order runs from the month in which DRP directions are received. The text states that the directions were uploaded on the ITBA portal and emailed to the AO on 27.06.2024, with delivery established on that date; therefore receipt occurred electronically then, not later on physical delivery. On that basis, the limitation expired on 31.07.2024, and the assessment order passed on 27.08.2024 was time-barred and quashed; the remaining grounds were left academic.
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Acts Income Tax
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