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    August 27, 2026   Case Laws Income Tax
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August 27, 2026   Case Laws Income Tax
Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation entries.
August 27, 2026   Case Laws Income Tax
Educational charitable status upheld for banking-sector training, preserving exemption, valid income accumulation, and depreciation relief.
August 27, 2026   Case Laws Income Tax
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivables.
August 27, 2026   Case Laws Income Tax
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verification.
August 27, 2026   Case Laws Income Tax
Trademark licensing fees remain revenue expenditure where use is limited, non-exclusive, time-bound, and creates no enduring proprietary asset.
August 27, 2026   Case Laws Income Tax
Unbilled Revenue Reversal and Non-Resident Professional Fees: prior taxation and treaty royalty analysis defeated both disallowances.
August 27, 2026   Case Laws Income Tax
Professional-fee penalty requires substantiated claims and proven tax-deduction liability; unsupported claims may still attract penalty.
August 27, 2026   Case Laws Income Tax
Deemed concealment penalty fails where pre-notice TDS exceeds assessed tax, leaving no tax sought to be evaded.
August 27, 2026   Case Laws Income Tax
Redevelopment project accounting: incomparable profit estimates and uncorroborated survey statements cannot justify additions or book rejection.
August 27, 2026   Case Laws Customs
Customs custodian liability for pilfered imports applies independently after valid approval, despite separate bailee obligations under port law.
August 27, 2026   Case Laws Customs
Customs agency liability requires proof of authority and knowledge; unsupported duty demands and penalties cannot stand.
August 27, 2026   Case Laws Customs
Mixed-lot fabric classification requires evidence of actual composition, defeating unsupported reclassification, differential duty, interest and penalty.
August 27, 2026   Case Laws Customs
Corroboration of accomplice statements is essential before personal penalties for alleged gold-smuggling abetment can be sustained.
August 27, 2026   Case Laws Customs
Residuary customs penalty cannot apply to voluntarily disclosed invoice omissions where specific penal provisions govern the conduct.
August 27, 2026   Case Laws Customs
Classification of water-insoluble surface-active products follows Heading 3824 when Chapter 34 water-mixture requirements are not met.
August 27, 2026   Case Laws Customs
SEZ-to-DTA duty timing prevents differential-duty bank guarantees before authorised operations and permits release on a value-based bond.
August 27, 2026   Case Laws Customs
Retracted customs statements require cross-examination before supporting gold confiscation or penalties under the statutory evidentiary framework.
August 27, 2026   Case Laws Companies Law
Authorization to institute disgorgement proceedings need not delegate statutory power where SFIO only implements the Government's decision.
August 27, 2026   Case Laws Companies Law
Approved resolution plan primacy bars rectification claims seeking revival of extinguished equity and consequential monetary or share-based reliefs.
August 27, 2026   Case Laws IBC
Natural justice in insolvency-professional discipline requires disclosed material; notices based on extraneous material and ignored defences are vitiated.

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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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