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    August 25, 2026   Case Laws Income Tax
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    Intra-group management-fee adjustment deleted; tax refunds, TDS credit and interest charges require factual verification or recomputation.
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August 25, 2026   Case Laws Income Tax
Agricultural land classification requires cumulative factual indicators, while industrial-purpose land and absent agricultural use defeat reinvestment relief claims.
August 25, 2026   Case Laws Income Tax
Previous owner's holding period determines long-term capital gains status and indexation for property devolved through a family trust.
August 25, 2026   Case Laws Income Tax
Interest income classification and linked borrowing costs: income from other sources retains treatment, with nexus-based deduction available.
August 25, 2026   Case Laws Income Tax
Professional income estimation cannot treat gross receipts as net income solely for non-filing of a tax return.
August 25, 2026   Case Laws Income Tax
Delayed property conveyance perfecting pre-existing beneficial ownership does not trigger tax on inadequate consideration under section 56(2)(x).
August 25, 2026   Case Laws Income Tax
Outright trademark acquisition is capital expenditure, so foreign remittance attracts withholding only where income is chargeable to tax.
August 25, 2026   Case Laws Income Tax
NRE deposit interest exemption may continue after residential status changes if RBI or FEMA permission to maintain the account exists.
August 25, 2026   Case Laws Income Tax
Unaccounted real-estate consideration requires transaction-specific proof; price estimates and third-party loose sheets cannot establish alleged cash payments.
August 25, 2026   Case Laws Income Tax
Form 10-IC option under concessional corporate taxation continues for subsequent years without annual refiling requirements.
August 25, 2026   Case Laws Income Tax
Depreciation as charitable application remains available where fixed-asset acquisition cost was not previously claimed as income application.
August 25, 2026   Case Laws Income Tax
Segmental TNMM benchmarking prevents duplicate adjustments for integral intra-group support services under an assured-margin operating model.
August 25, 2026   Case Laws Income Tax
Composite residential flat exemption upheld where supplementary agreement merged adjoining units and additional evidence supported the taxpayer's investment claim.
August 25, 2026   Case Laws Income Tax
Interest expenditure nexus with income-producing assets permits full section 57 deduction without capping it to annual interest income.
August 25, 2026   Case Laws Income Tax
Intra-group management-fee adjustment deleted; tax refunds, TDS credit and interest charges require factual verification or recomputation.
August 25, 2026   Case Laws Income Tax
Associated-enterprise status requires participation in management, control or capital; commercial dependence alone cannot disqualify an internal CUP.
August 25, 2026   Case Laws Income Tax
Renewable Energy Certificate proceeds are capital receipts, excluded from eligible business-profit deductions and minimum alternate tax book profit.
August 25, 2026   Case Laws Customs
Prospective operation of customs exemptions prevents reliance on later amendments when considering provisional release of imported goods
August 25, 2026   Case Laws Customs
Proportionate Customs Broker discipline limits appellate interference where the original penalty decision is neither arbitrary nor legally infirm.
August 25, 2026   Case Laws SEBI
Urgent interim relief exception permits commercial suit without pre-institution mediation where immediate disclosure and asset protection are genuinely required.
August 25, 2026   Case Laws Indian Laws
Registrar's power to amend service rules survives circular nomenclature and non-compliance with a directory legislative laying requirement.

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

COVID-19 adjustments in transfer-pricing benchmarking require...

Transfer-pricing benchmarking requires proven COVID costs, consistent TNMM classifications, and reliable internal CUP comparability before adjustments.

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Income Tax September 1, 2026 Case Laws AT
COVID-19 adjustments in transfer-pricing benchmarking require proof of exceptional pandemic expenditure, its non-operating character, and a materially different impact on comparables; pandemic timing alone is insufficient. TNMM also requires consistent treatment of operating and non-operating items for the tested party and comparables, including foreign-exchange effects from revenue transactions and depreciation on business assets. Internal CUP for software support services requires transaction-level comparability of contractual scope, functions, assets, risks, personnel, volume, duration and market conditions, with reliable adjustments for material differences. Transfer-pricing adjustments were remanded for fresh verification and benchmarking. A final assessment following timely draft assessment and DRP directions remains within the separate DRP-related limitation period.
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