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    September 9, 2026   Case Laws Income Tax
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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.
September 9, 2026   Case Laws Customs
Customs-duty exemption for salvage-operation stores concerns duty rates, requiring a direct Supreme Court challenge rather than High Court appeal.
September 9, 2026   Case Laws Customs
Bank account freezing under Customs law cannot continue beyond the statutory maximum merely because a show-cause notice was issued.
September 9, 2026   Case Laws Customs
Restricted gold import conditions: breach permits absolute confiscation, while redemption remains discretionary and is rarely disturbed on writ review.
September 9, 2026   Case Laws Customs
Written acceptance of customs reassessment does not waive appeal rights where enhanced valuation is paid under protest.
September 9, 2026   Case Laws Customs
Pre-import condition breach under Advance Authorisation requires Bill of Entry-wise IGST reassessment, while interest and penalties fail.
September 9, 2026   Case Laws Customs
Customs valuation safeguards invalidate unsupported declared-value rejection, unauthenticated electronic evidence, proxy-importer duty demands, and redemption fine.

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Income Tax

Period of limitation for passing the penalty order u/s 275(1)(a)...

Income Tax Act limits penalty order issuance to 6 months after Tribunal's order receipt by Chief Commissioner.

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Income Tax November 4, 2013 Case Laws AT
Period of limitation for passing the penalty order u/s 275(1)(a) - the limitation period for the levy of penalty will be as provided for under s. 275(1)(a), i.e., six months from the end of the month in which the order of the Tribunal is received by the Chief CIT - AT
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