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    September 9, 2026   Case Laws GST
    Prior appellate resolution bars an unreconciled subsequent tax adjudication order and its consequential bank recovery notice.
    September 9, 2026   Case Laws GST
    Merits-Based GST Refund Appeals Require Reasoned Decisions, Preventing Dismissal Solely for Non-Appearance and Requiring Fresh Adjudication
    September 9, 2026   Case Laws GST
    GST appeal limitation may yield where uncontrollable delay would deny merits review and cause grave prejudice.
    September 9, 2026   Case Laws GST
    Electronic GST notice service remains valid when uploaded to the taxpayer's portal; failure to monitor it cannot defeat assessment.
    September 9, 2026   Case Laws Income Tax
    Compounding charge timelines run from complaint service, preventing enhanced charges for promptly filed accused applications.
    September 9, 2026   Case Laws Income Tax
    Transparent political-donation deduction claims do not alone constitute misreporting, permitting statutory immunity from under-reporting penalties.
    September 9, 2026   Case Laws Income Tax
    Charitable sports promotion: sponsorship receipts alone did not defeat registration where funds supported tournaments and player development activitie...
    September 9, 2026   Case Laws Income Tax
    Misreporting penalty requires evidence of deliberate inaccuracy, not merely withdrawal of a disclosed donation deduction claim during reassessment.
    September 9, 2026   Case Laws Income Tax
    Overdue associated-enterprise receivables: debt-free status defeated notional-interest adjustment, while employee stock-option costs qualified as busi...
    September 9, 2026   Case Laws Income Tax
    Retrospective assessment-limitation amendments validate final orders while contemporaneous segment data governs transfer-pricing comparability and tol...
    September 9, 2026   Case Laws Income Tax
    Transfer pricing adjustments must track international transactions, while unsupported AMP adjustments and unsuitable manufacturing comparables require...
    September 9, 2026   Case Laws Income Tax
    Internal comparable Cost Plus Method prevails where identical independent services use the same mark-up, eliminating transfer-pricing adjustment.
    September 9, 2026   Case Laws Income Tax
    Telecom tax deductions and transfer pricing: business-linked receipts qualify, while unsupported royalty and marketing adjustments fail.
    September 9, 2026   Case Laws Income Tax
    Unexercised stock option compensation remains non-salary when voluntary restructuring payments lack a proximate employment nexus and option transfer.
    September 9, 2026   Case Laws Income Tax
    Notional letting value on unsold stock-in-trade and unsupported brokerage benchmarking cannot sustain tax adjustments for pre-amendment years.
    September 9, 2026   Case Laws Income Tax
    Consequential assessment limitation bars reassessment after a partial transfer-pricing remand unless the statutory deadline is met.
    September 9, 2026   Case Laws Income Tax
    TNMM functional comparability drives exclusions, current-year recession margins, operating-income treatment, and deletion of interest imputation on de...
    September 9, 2026   Case Laws Income Tax
    Suppressed turnover taxability limits assessment to embedded profit, while cash-payment disallowance requires payment-wise threshold verification.
    September 9, 2026   Case Laws Income Tax
    Transfer-pricing adjustments must reflect functional comparability, working-capital effects, and avoid duplicating interest on associated-enterprise r...
    September 9, 2026   Case Laws Income Tax
    Transfer pricing consistency under TNMM protects integrated intra-group service benchmarking where facts and business model remain unchanged.
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September 9, 2026   Case Laws GST
Prior appellate resolution bars an unreconciled subsequent tax adjudication order and its consequential bank recovery notice.
September 9, 2026   Case Laws GST
Merits-Based GST Refund Appeals Require Reasoned Decisions, Preventing Dismissal Solely for Non-Appearance and Requiring Fresh Adjudication
September 9, 2026   Case Laws GST
GST appeal limitation may yield where uncontrollable delay would deny merits review and cause grave prejudice.
September 9, 2026   Case Laws GST
Electronic GST notice service remains valid when uploaded to the taxpayer's portal; failure to monitor it cannot defeat assessment.
September 9, 2026   Case Laws Income Tax
Compounding charge timelines run from complaint service, preventing enhanced charges for promptly filed accused applications.
September 9, 2026   Case Laws Income Tax
Transparent political-donation deduction claims do not alone constitute misreporting, permitting statutory immunity from under-reporting penalties.
September 9, 2026   Case Laws Income Tax
Charitable sports promotion: sponsorship receipts alone did not defeat registration where funds supported tournaments and player development activities.
September 9, 2026   Case Laws Income Tax
Misreporting penalty requires evidence of deliberate inaccuracy, not merely withdrawal of a disclosed donation deduction claim during reassessment.
September 9, 2026   Case Laws Income Tax
Overdue associated-enterprise receivables: debt-free status defeated notional-interest adjustment, while employee stock-option costs qualified as business expenditure.
September 9, 2026   Case Laws Income Tax
Retrospective assessment-limitation amendments validate final orders while contemporaneous segment data governs transfer-pricing comparability and tolerance-band verification.
September 9, 2026   Case Laws Income Tax
Transfer pricing adjustments must track international transactions, while unsupported AMP adjustments and unsuitable manufacturing comparables require exclusion.
September 9, 2026   Case Laws Income Tax
Internal comparable Cost Plus Method prevails where identical independent services use the same mark-up, eliminating transfer-pricing adjustment.
September 9, 2026   Case Laws Income Tax
Telecom tax deductions and transfer pricing: business-linked receipts qualify, while unsupported royalty and marketing adjustments fail.
September 9, 2026   Case Laws Income Tax
Unexercised stock option compensation remains non-salary when voluntary restructuring payments lack a proximate employment nexus and option transfer.
September 9, 2026   Case Laws Income Tax
Notional letting value on unsold stock-in-trade and unsupported brokerage benchmarking cannot sustain tax adjustments for pre-amendment years.
September 9, 2026   Case Laws Income Tax
Consequential assessment limitation bars reassessment after a partial transfer-pricing remand unless the statutory deadline is met.
September 9, 2026   Case Laws Income Tax
TNMM functional comparability drives exclusions, current-year recession margins, operating-income treatment, and deletion of interest imputation on debt-free receivables.
September 9, 2026   Case Laws Income Tax
Suppressed turnover taxability limits assessment to embedded profit, while cash-payment disallowance requires payment-wise threshold verification.
September 9, 2026   Case Laws Income Tax
Transfer-pricing adjustments must reflect functional comparability, working-capital effects, and avoid duplicating interest on associated-enterprise receivables.
September 9, 2026   Case Laws Income Tax
Transfer pricing consistency under TNMM protects integrated intra-group service benchmarking where facts and business model remain unchanged.

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Income Tax

Functional comparability governs selection of software...

Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-capital adjustments require verification.

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Income Tax September 1, 2026 Case Laws AT
Functional comparability governs selection of software development support service comparables. Entities undertaking enterprise transformation, software-product or diversified activities, onsite services, product development or research and development, without reliable segmental information, do not meet the benchmark for routine software development support services and are excluded. The functional profiles of two proposed comparables require fresh examination. Inclusion of another comparable depends on verification of its related-party transaction computation under the applicable filter. Weighted-average operating margins and working-capital adjustments for software development and sales and marketing support services require verification and recomputation. Slump-sale gains and employee-benefit deduction claims also require factual verification, with interest and penalty issues following consequentially.
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Acts Income Tax
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