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    October 13, 2026   Case Laws Income Tax
    Aggregation of linked transfer-pricing transactions validated netted know-how fees, while unsupported director incentive disallowance could not stand.
    October 13, 2026   Case Laws Income Tax
    Crystallisation of liability supports prior-period expense deduction, while functionally distinct divisions require separate transfer-pricing benchmar...
    October 13, 2026   Case Laws Income Tax
    Manufacturing scrap deductions and exempt-income disallowance safeguards upheld, while royalty benchmarking proceeds for fresh transfer-pricing review...
    October 13, 2026   Case Laws Income Tax
    Vivad Se Vishwas settlement scope excludes independent reassessment disputes, while unsupported bogus-purchase additions require disclosed transaction...
    October 13, 2026   Case Laws Income Tax
    Functional comparability under TNMM requires transaction-specific FAR analysis before benchmarking business-support services provided to associated en...
    October 13, 2026   Case Laws Income Tax
    Omitted specified-domestic-transaction rules invalidated transfer-pricing adjustments, while derivative losses and exempt-income expenditure limits re...
    October 13, 2026   Case Laws Income Tax
    Advance pricing agreement methodology can guide benchmarking for non-covered years when functions, assets, risks and activities remain materially unch...
    October 13, 2026   Case Laws Income Tax
    MAT credit succession on amalgamation allows a transferee to claim available unutilised credit under a sanctioned scheme, subject to verification.
    October 13, 2026   Case Laws Income Tax
    Advertisement expenditure as brand-promotion service requires proof of an arrangement; adjustment deleted and other tax computations remanded.
    October 13, 2026   Case Laws Income Tax
    Tax-audit exemption for substantially State-funded educational universities prevents audit-failure penalties where income qualifies for statutory exem...
    October 13, 2026   Case Laws Income Tax
    Notional interest on delayed trade receivables may be deleted when financial records verify the taxpayer is completely debt-free.
    October 13, 2026   Case Laws Income Tax
    Functional, asset and risk analysis excludes diversified technology companies from captive software development comparables under cost-plus arrangemen...
    October 13, 2026   Case Laws Income Tax
    Retracted search surrenders without corroboration cannot sustain undisclosed-income additions; no section 14A disallowance arises without exempt incom...
    October 13, 2026   Case Laws Income Tax
    Charitable trust registration cancellation requires proof of non-genuine activities, while year-specific irregular receipts remain assessment matters.
    October 13, 2026   Case Laws Benami Property
    Benami cash routing through third-party bank accounts permits attachment of remaining balances and traceable converted funds.
    October 13, 2026   Case Laws Customs
    Rectification jurisdiction excludes merits review where objections challenge concluded penalty findings rather than patent errors on the record.
    October 13, 2026   Case Laws Customs
    Mobile-phone electronic evidence failed to establish customs undervaluation, while duty survived on non-authentic origin certificates without importer...
    October 13, 2026   Case Laws Customs
    Customs reassessment acceptance preserves challenge rights where transaction value is rejected solely on unsupported NIDB data.
    October 13, 2026   Case Laws Customs
    Furnace re-lining refractories qualify as EPCG capital goods, securing zero-duty import benefits and eliminating related customs demands.
    October 13, 2026   Case Laws Customs
    Automotive radio classification treats integrated infotainment features as supplementary, placing complete and qualifying unassembled units under the ...
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October 13, 2026   Case Laws Income Tax
Aggregation of linked transfer-pricing transactions validated netted know-how fees, while unsupported director incentive disallowance could not stand.
October 13, 2026   Case Laws Income Tax
Crystallisation of liability supports prior-period expense deduction, while functionally distinct divisions require separate transfer-pricing benchmarking.
October 13, 2026   Case Laws Income Tax
Manufacturing scrap deductions and exempt-income disallowance safeguards upheld, while royalty benchmarking proceeds for fresh transfer-pricing review.
October 13, 2026   Case Laws Income Tax
Vivad Se Vishwas settlement scope excludes independent reassessment disputes, while unsupported bogus-purchase additions require disclosed transaction particulars.
October 13, 2026   Case Laws Income Tax
Functional comparability under TNMM requires transaction-specific FAR analysis before benchmarking business-support services provided to associated enterprises.
October 13, 2026   Case Laws Income Tax
Omitted specified-domestic-transaction rules invalidated transfer-pricing adjustments, while derivative losses and exempt-income expenditure limits remained sustainable.
October 13, 2026   Case Laws Income Tax
Advance pricing agreement methodology can guide benchmarking for non-covered years when functions, assets, risks and activities remain materially unchanged.
October 13, 2026   Case Laws Income Tax
MAT credit succession on amalgamation allows a transferee to claim available unutilised credit under a sanctioned scheme, subject to verification.
October 13, 2026   Case Laws Income Tax
Advertisement expenditure as brand-promotion service requires proof of an arrangement; adjustment deleted and other tax computations remanded.
October 13, 2026   Case Laws Income Tax
Tax-audit exemption for substantially State-funded educational universities prevents audit-failure penalties where income qualifies for statutory exemption.
October 13, 2026   Case Laws Income Tax
Notional interest on delayed trade receivables may be deleted when financial records verify the taxpayer is completely debt-free.
October 13, 2026   Case Laws Income Tax
Functional, asset and risk analysis excludes diversified technology companies from captive software development comparables under cost-plus arrangements.
October 13, 2026   Case Laws Income Tax
Retracted search surrenders without corroboration cannot sustain undisclosed-income additions; no section 14A disallowance arises without exempt income.
October 13, 2026   Case Laws Income Tax
Charitable trust registration cancellation requires proof of non-genuine activities, while year-specific irregular receipts remain assessment matters.
October 13, 2026   Case Laws Benami Property
Benami cash routing through third-party bank accounts permits attachment of remaining balances and traceable converted funds.
October 13, 2026   Case Laws Customs
Rectification jurisdiction excludes merits review where objections challenge concluded penalty findings rather than patent errors on the record.
October 13, 2026   Case Laws Customs
Mobile-phone electronic evidence failed to establish customs undervaluation, while duty survived on non-authentic origin certificates without importer penalties.
October 13, 2026   Case Laws Customs
Customs reassessment acceptance preserves challenge rights where transaction value is rejected solely on unsupported NIDB data.
October 13, 2026   Case Laws Customs
Furnace re-lining refractories qualify as EPCG capital goods, securing zero-duty import benefits and eliminating related customs demands.
October 13, 2026   Case Laws Customs
Automotive radio classification treats integrated infotainment features as supplementary, placing complete and qualifying unassembled units under the radio tariff heading.

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Functional, asset and risk analysis requires comparables for a...

Functional, asset and risk analysis excludes diversified technology companies from captive software development comparables under cost-plus arrangements.

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Income Tax October 13, 2026 Case Laws AT
Functional, asset and risk analysis requires comparables for a captive software development service provider to reflect its limited-risk, cost-plus operating model. Diversified technology companies with broad service portfolios, substantial brand value and intangibles, significant research and development, goodwill, patents, and different risk profiles are functionally dissimilar. The absence of standalone segmental information further impairs reliable comparison. Infosys Ltd., Wipro Ltd. and LTI Mindtree Ltd. are therefore unsuitable comparables, requiring recomputation of any transfer-pricing adjustment after their exclusion.
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Acts Income Tax
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