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    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.
    September 9, 2026   Case Laws Income Tax
    Reassessment based on specific investigation information upheld where alleged accommodation-entry loan showed a live nexus with escaped income.
    September 9, 2026   Case Laws Income Tax
    Working capital adjustments require reasonably accurate computations, while CSR donations may qualify separately for charitable deduction.
    September 9, 2026   Case Laws Income Tax
    AE segmental benchmarking and CCD interest deductions survive disclosure reclassification where arm's-length margins and debt status are established.
    September 9, 2026   Case Laws Customs
    Interim stay exclusion under customs limitation begins when connected writ protection ends, preserving timely duty adjudication.
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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.
September 9, 2026   Case Laws Income Tax
Reassessment based on specific investigation information upheld where alleged accommodation-entry loan showed a live nexus with escaped income.
September 9, 2026   Case Laws Income Tax
Working capital adjustments require reasonably accurate computations, while CSR donations may qualify separately for charitable deduction.
September 9, 2026   Case Laws Income Tax
AE segmental benchmarking and CCD interest deductions survive disclosure reclassification where arm's-length margins and debt status are established.
September 9, 2026   Case Laws Customs
Interim stay exclusion under customs limitation begins when connected writ protection ends, preserving timely duty adjudication.

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

The test of human probabilities permits tax authorities to look...

Human-probability test defeats political donation deduction where banking records mask accommodation-entry fund layering and evidence shows non-genuine contributions.

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Income Tax September 25, 2026 Case Laws AT
The test of human probabilities permits tax authorities to look beyond documentary evidence and banking-channel payments when assessing the real nature of a political contribution. Donation receipts and bank payments did not prove genuineness where investigation material, statements, bank-trail analysis, and the recipient party's modus operandi showed systematic fund layering for accommodation entries. The apparent transaction was not a genuine political contribution; the claimed deduction was denied, the consequential addition sustained, and the assessee's appeal dismissed.
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