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    October 21, 2026   Case Laws Income Tax
    Final assessment limitation follows DRP-specific timelines when the draft order is timely, despite expiry of general assessment limits.
    October 21, 2026   Case Laws Income Tax
    Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
    October 21, 2026   Case Laws Income Tax
    Accommodation-entry loan additions require evidence beyond generic third-party allegations, while interest disallowance needs proof of actual incurren...
    October 21, 2026   Case Laws Income Tax
    Comparable uncontrolled price method requires actual uncontrolled transactions, resulting in deletion of unsupported related-party loan interest adjus...
    October 21, 2026   Case Laws Income Tax
    Limitation for section 271D penalties requires a timely order, making orders beyond the statutory period invalid.
    October 21, 2026   Case Laws Income Tax
    Service of reassessment notice remains a jurisdictional precondition; participation after inquiry notice cannot cure non-service.
    October 21, 2026   Case Laws Income Tax
    Reassessment based on third-party information upheld, while profit element in fictitious purchases remains subject to estimated disallowance.
    October 21, 2026   Case Laws Income Tax
    Notice under section 143(2) is mandatory for section 153C assessments, and its complete absence invalidates assessments.
    October 21, 2026   Case Laws Income Tax
    Search assessment jurisdiction requires a valid assessment block, asset-linked escaped income, incriminating material, and timely completion.
    October 21, 2026   Case Laws Income Tax
    Royalty benchmarking requires reliable uncontrolled comparables, supporting TNMM aggregation where technical know-how payments are tied to manufacturi...
    October 21, 2026   Case Laws Income Tax
    Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
    October 21, 2026   Case Laws Income Tax
    Year-end accruals under consistent accounting remain deductible; duplicate taxation, invalid remands, and uninitiated penalties cannot stand.
    October 21, 2026   Case Laws Customs
    Sufficient cause for delayed Customs appeals excludes unexplained administrative inaction and unsupported blame placed on former counsel.
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October 21, 2026   Case Laws Income Tax
Final assessment limitation follows DRP-specific timelines when the draft order is timely, despite expiry of general assessment limits.
October 21, 2026   Case Laws Income Tax
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unestablished.
October 21, 2026   Case Laws Income Tax
Accommodation-entry loan additions require evidence beyond generic third-party allegations, while interest disallowance needs proof of actual incurrence.
October 21, 2026   Case Laws Income Tax
Comparable uncontrolled price method requires actual uncontrolled transactions, resulting in deletion of unsupported related-party loan interest adjustment.
October 21, 2026   Case Laws Income Tax
Limitation for section 271D penalties requires a timely order, making orders beyond the statutory period invalid.
October 21, 2026   Case Laws Income Tax
Service of reassessment notice remains a jurisdictional precondition; participation after inquiry notice cannot cure non-service.
October 21, 2026   Case Laws Income Tax
Reassessment based on third-party information upheld, while profit element in fictitious purchases remains subject to estimated disallowance.
October 21, 2026   Case Laws Income Tax
Notice under section 143(2) is mandatory for section 153C assessments, and its complete absence invalidates assessments.
October 21, 2026   Case Laws Income Tax
Search assessment jurisdiction requires a valid assessment block, asset-linked escaped income, incriminating material, and timely completion.
October 21, 2026   Case Laws Income Tax
Royalty benchmarking requires reliable uncontrolled comparables, supporting TNMM aggregation where technical know-how payments are tied to manufacturing operations.
October 21, 2026   Case Laws Income Tax
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and transfer-pricing principles.
October 21, 2026   Case Laws Income Tax
Year-end accruals under consistent accounting remain deductible; duplicate taxation, invalid remands, and uninitiated penalties cannot stand.
October 21, 2026   Case Laws Customs
Sufficient cause for delayed Customs appeals excludes unexplained administrative inaction and unsupported blame placed on former counsel.
October 21, 2026   Case Laws Customs
Proportionality in Customs Broker licence revocation protects brokers where employee misconduct lacks deliberate broker involvement or repeated violations.
October 21, 2026   Case Laws Customs
Essential character determines classification of multifunctional car radio units and qualifying SKD kits as automotive radio receivers.
October 21, 2026   Case Laws Companies Law
Reasoned SFIO investigation orders require discernible statutory grounds; later material cannot cure a defective initiation.
October 21, 2026   Case Laws IBC
Financial debt requires time value of money; share-purchase consideration without a repayment obligation cannot support insolvency proceedings.
October 21, 2026   Case Laws IBC
Pre-existing quality disputes restrict insolvency admission where credible contemporaneous evidence requires fuller determination in appropriate proceedings.
October 21, 2026   Case Laws IBC
Disciplinary proportionality requires penalties for Authorised Representative misconduct to match proven harm, leading to reconsideration of registration cancellation.
October 21, 2026   Case Laws FEMA
Reasoned FEMA penalty orders must disclose evidence supporting liability; an unexplained affirmance requires fresh adjudication.

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

Jurisdiction over an amalgamating company ends when it ceases to...

Jurisdiction over amalgamating companies fails when TDS orders target entities that ceased to exist after notified amalgamation.

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Income Tax October 7, 2026 Case Laws AT
Jurisdiction over an amalgamating company ends when it ceases to exist following amalgamation. A section 201 order issued and served in the former company's name, despite prior notification to the TDS authority, suffers a jurisdictional defect; referring to the successor company in the body of the order does not cure it. The order was void ab initio and quashed, while the issue of interest under section 201(1A) remained academic.
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