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    July 21, 2026   Case LawsGST
    Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
    July 21, 2026   Case LawsGST
    Clarificatory duty drawback circulars operate retrospectively, preserving merchant exporters' existing entitlement and supporting refund interest afte...
    July 21, 2026   Case LawsGST
    State GST officers' IGST enforcement powers extend to confiscation, with challenges routed through the State statutory appeal mechanism.
    July 21, 2026   Case LawsGST
    University affiliation fees are described as non-taxable regulatory functions, alternatively protected by the educational-services GST exemption.
    July 21, 2026   Case LawsGST
    Wrong-head integrated tax payment requires statutory adjustment before intra-State tax, interest, or penalty liability is determined afresh.
    July 21, 2026   Case LawsGST
    Restaurant service classification excludes hookah flavours consumed by inhalation, notwithstanding accompanying food, beverages and attendant restaura...
    July 21, 2026   Case LawsIncome Tax
    Rectification jurisdiction permits only correction of apparent record errors, not recall or reconsideration of a detailed merits order.
    July 21, 2026   Case LawsIncome Tax
    Residential property investment under Section 54F remains eligible despite delayed completion, possession or registration beyond the taxpayer's contro...
    July 21, 2026   Case LawsIncome Tax
    Royalty benchmarking under TNMM prevails where domestic rates lack reliable comparability for export transactions and technical know-how use.
    July 21, 2026   Case LawsIncome Tax
    Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
    July 21, 2026   Case LawsIncome Tax
    Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
    July 21, 2026   Case LawsIncome Tax
    Statutory approval under reassessment rules is jurisdictional; sanction by an incompetent authority invalidates the notice and reassessment.
    July 21, 2026   Case LawsIncome Tax
    Insurance compensation adjusted against fire loss cannot be separately taxed, and the consequential concealment penalty fails.
    July 21, 2026   Case LawsIncome Tax
    Securitisation trust pass-through taxation applies where investors lack voluntary common design and retain revocation rights over contributions.
    July 21, 2026   Case LawsIncome Tax
    Mandatory prior notice for bank-account attachment requires release where the assessee was not informed before recovery action.
    July 21, 2026   Case LawsIncome Tax
    Bona fide cash accounting for unpaid loan interest permits exclusion of accrued but unrealised income when consistently disclosed.
    July 21, 2026   Case LawsBenami Property
    Doctrine of election barred inconsistent ownership claims, while testamentary office permission created no life interest or possessory right.
    July 21, 2026   Case LawsCustoms
    Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
    July 21, 2026   Case LawsCustoms
    Aluminium formwork classification turns on its on-site shuttering function, supporting treatment as aluminium structures rather than moulds.
    July 21, 2026   Case LawsCustoms
    Aluminium formwork used as concrete shuttering is classified as aluminium structures, not as moulds for concrete articles.
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    July 21, 2026   Case Laws GST
    Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed.
    July 21, 2026   Case Laws GST
    Clarificatory duty drawback circulars operate retrospectively, preserving merchant exporters' existing entitlement and supporting refund interest after unlawful recovery.
    July 21, 2026   Case Laws GST
    State GST officers' IGST enforcement powers extend to confiscation, with challenges routed through the State statutory appeal mechanism.
    July 21, 2026   Case Laws GST
    University affiliation fees are described as non-taxable regulatory functions, alternatively protected by the educational-services GST exemption.
    July 21, 2026   Case Laws GST
    Wrong-head integrated tax payment requires statutory adjustment before intra-State tax, interest, or penalty liability is determined afresh.
    July 21, 2026   Case Laws GST
    Restaurant service classification excludes hookah flavours consumed by inhalation, notwithstanding accompanying food, beverages and attendant restaurant facilities.
    July 21, 2026   Case Laws Income Tax
    Rectification jurisdiction permits only correction of apparent record errors, not recall or reconsideration of a detailed merits order.
    July 21, 2026   Case Laws Income Tax
    Residential property investment under Section 54F remains eligible despite delayed completion, possession or registration beyond the taxpayer's control.
    July 21, 2026   Case Laws Income Tax
    Royalty benchmarking under TNMM prevails where domestic rates lack reliable comparability for export transactions and technical know-how use.
    July 21, 2026   Case Laws Income Tax
    Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any adjustment.
    July 21, 2026   Case Laws Income Tax
    Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classification.
    July 21, 2026   Case Laws Income Tax
    Statutory approval under reassessment rules is jurisdictional; sanction by an incompetent authority invalidates the notice and reassessment.
    July 21, 2026   Case Laws Income Tax
    Insurance compensation adjusted against fire loss cannot be separately taxed, and the consequential concealment penalty fails.
    July 21, 2026   Case Laws Income Tax
    Securitisation trust pass-through taxation applies where investors lack voluntary common design and retain revocation rights over contributions.
    July 21, 2026   Case Laws Income Tax
    Mandatory prior notice for bank-account attachment requires release where the assessee was not informed before recovery action.
    July 21, 2026   Case Laws Income Tax
    Bona fide cash accounting for unpaid loan interest permits exclusion of accrued but unrealised income when consistently disclosed.
    July 21, 2026   Case Laws Benami Property
    Doctrine of election barred inconsistent ownership claims, while testamentary office permission created no life interest or possessory right.
    July 21, 2026   Case Laws Customs
    Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutiny.
    July 21, 2026   Case Laws Customs
    Aluminium formwork classification turns on its on-site shuttering function, supporting treatment as aluminium structures rather than moulds.
    July 21, 2026   Case Laws Customs
    Aluminium formwork used as concrete shuttering is classified as aluminium structures, not as moulds for concrete articles.

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

      Transfer-pricing comparability requires functional similarity...

      Transfer-pricing comparability requires functional similarity and current-year segmental data, supporting exclusion of materially different packaging companies.

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      Income TaxAugust 14, 2026Case LawsHC
      Transfer-pricing comparability requires functional similarity and reliable current-year segmental data. Bilcare Ltd. was excluded because of diversified operations, unavailable segmental data, and its pharmaceutical packaging profile, which differed from paper-based aseptic packaging for food and drink products. Karur KCP Packaging Ltd. was excluded because it produced kraft paper and polypropylene bags principally for the cement industry, making its products materially dissimilar. Earlier-year segmental data could not support current-year inclusion where relevant data was unavailable. The Tribunal's fact-based comparability findings disclosed neither error nor perversity, so no substantial question of law arose and the Revenue's appeal was dismissed; the separate Revenue appeal issue remained open.
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