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    September 10, 2026   Case Laws Income Tax
    Condonation for revised returns may prevent double taxation when reporting-statement revisions cause genuine taxpayer hardship.
    September 10, 2026   Case Laws Income Tax
    Income-tax prosecution fails when appellate remand removes its factual foundation; directors require company arraignment for vicarious criminal liabil...
    September 10, 2026   Case Laws Income Tax
    Transfer-pricing comparability requires functionally similar, uncontrolled companies, with turnover, related-party transactions and risk profiles asse...
    September 10, 2026   Case Laws Income Tax
    Interim protection from outstanding-demand recovery continues while the statutory appeal receives expedited, reasoned disposal after a hearing.
    September 10, 2026   Case Laws Income Tax
    Capital character of assignment consideration prevents taxation as residuary income, while unsupported interest-related expenditure remains non-deduct...
    September 10, 2026   Case Laws Income Tax
    Make-available condition shields regional support-service receipts from Indian taxation where no independent capability or permanent establishment exi...
    September 10, 2026   Case Laws Income Tax
    Excess business stock with a proven business nexus remains undisclosed business income and is taxed under normal provisions.
    September 10, 2026   Case Laws Income Tax
    Dematerialised share-sale evidence and banking records defeat unsupported allegations of bogus long-term capital gains and unexplained credits.
    September 10, 2026   Case Laws Income Tax
    Transfer-pricing treatment of corporate guarantees and convertible loans followed prior-year consistency, with taxable foreign dividends excluded from...
    September 10, 2026   Case Laws Income Tax
    Characterisation of allotment rights determines whether transfer losses are business losses or capital losses and affects interest-cost computation.
    September 10, 2026   Case Laws Income Tax
    Unconverted FCCDs remain debentures until conversion, so their issue consideration falls outside share-premium taxation provisions.
    September 10, 2026   Case Laws Income Tax
    Transfer-pricing benchmarking confines adjustments to associated-enterprise transactions and integrates delayed receivables through TNMM working-capit...
    September 10, 2026   Case Laws Income Tax
    Joint development transfer timing and firm-held rental income: effective possession fixes the capital-gains year and defeats later additions.
    September 10, 2026   Case Laws Income Tax
    Section 153D approval requires independent, year-wise scrutiny; mechanical consolidated approval invalidates the resulting search assessment order.
    September 10, 2026   Case Laws Customs
    Concurrent factual findings on fictitious imports precluded a substantial legal question, sustaining confiscation and penalties.
    September 10, 2026   Case Laws Income Tax
    Medical relief status protects government-contracted mobile healthcare from commercial classification, while provisional registration cancellation req...
    September 10, 2026   Case Laws Income Tax
    Charitable registration cancellation requires proof that educational activities abandoned their objects; incidental receipts and retained surplus are ...
    September 10, 2026   Case Laws Income Tax
    Export incentives under TNMM form operating income, requiring tested-party and arm's-length margins to be recomputed consistently.
    September 10, 2026   Case Laws Income Tax
    Third-party search material requires the prescribed assessment route and cannot support additions without cross-examination.
    September 10, 2026   Case Laws Customs
    Food safety testing of imported areca nuts requires examination by the competent authority, while Customs may pursue lawful further action.
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September 10, 2026   Case Laws Income Tax
Condonation for revised returns may prevent double taxation when reporting-statement revisions cause genuine taxpayer hardship.
September 10, 2026   Case Laws Income Tax
Income-tax prosecution fails when appellate remand removes its factual foundation; directors require company arraignment for vicarious criminal liability.
September 10, 2026   Case Laws Income Tax
Transfer-pricing comparability requires functionally similar, uncontrolled companies, with turnover, related-party transactions and risk profiles assessed on reliable data.
September 10, 2026   Case Laws Income Tax
Interim protection from outstanding-demand recovery continues while the statutory appeal receives expedited, reasoned disposal after a hearing.
September 10, 2026   Case Laws Income Tax
Capital character of assignment consideration prevents taxation as residuary income, while unsupported interest-related expenditure remains non-deductible.
September 10, 2026   Case Laws Income Tax
Make-available condition shields regional support-service receipts from Indian taxation where no independent capability or permanent establishment exists.
September 10, 2026   Case Laws Income Tax
Excess business stock with a proven business nexus remains undisclosed business income and is taxed under normal provisions.
September 10, 2026   Case Laws Income Tax
Dematerialised share-sale evidence and banking records defeat unsupported allegations of bogus long-term capital gains and unexplained credits.
September 10, 2026   Case Laws Income Tax
Transfer-pricing treatment of corporate guarantees and convertible loans followed prior-year consistency, with taxable foreign dividends excluded from exempt-income calculations.
September 10, 2026   Case Laws Income Tax
Characterisation of allotment rights determines whether transfer losses are business losses or capital losses and affects interest-cost computation.
September 10, 2026   Case Laws Income Tax
Unconverted FCCDs remain debentures until conversion, so their issue consideration falls outside share-premium taxation provisions.
September 10, 2026   Case Laws Income Tax
Transfer-pricing benchmarking confines adjustments to associated-enterprise transactions and integrates delayed receivables through TNMM working-capital adjustments.
September 10, 2026   Case Laws Income Tax
Joint development transfer timing and firm-held rental income: effective possession fixes the capital-gains year and defeats later additions.
September 10, 2026   Case Laws Income Tax
Section 153D approval requires independent, year-wise scrutiny; mechanical consolidated approval invalidates the resulting search assessment order.
September 10, 2026   Case Laws Customs
Concurrent factual findings on fictitious imports precluded a substantial legal question, sustaining confiscation and penalties.
September 10, 2026   Case Laws Income Tax
Medical relief status protects government-contracted mobile healthcare from commercial classification, while provisional registration cancellation requires specific notice.
September 10, 2026   Case Laws Income Tax
Charitable registration cancellation requires proof that educational activities abandoned their objects; incidental receipts and retained surplus are insufficient.
September 10, 2026   Case Laws Income Tax
Export incentives under TNMM form operating income, requiring tested-party and arm's-length margins to be recomputed consistently.
September 10, 2026   Case Laws Income Tax
Third-party search material requires the prescribed assessment route and cannot support additions without cross-examination.
September 10, 2026   Case Laws Customs
Food safety testing of imported areca nuts requires examination by the competent authority, while Customs may pursue lawful further action.

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

Transfer-pricing adjustment for intra-group management, sales...

Intra-group service pricing adjustment deleted after arm's length price was set at nil without sustainable basis.

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Income Tax September 1, 2026 Case Laws AT
Transfer-pricing adjustment for intra-group management, sales and support services was deleted after the Tribunal applied a co-ordinate Bench decision to the material facts. The adjustment had determined the arm's length price of those services at nil. The appeal was allowed on this issue, while the remaining grounds were left open.
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