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    June 23, 2026   Case Laws FEMA
    FERA show-cause notices after repeal were quashed for lack of jurisdiction under the FEMA savings scheme
    June 23, 2026   Case Laws GST
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    Advertising contract classification for Google AdWords payments prevailed over technical services treatment, so Section 194C TDS applied.
    June 23, 2026   Case Laws Income Tax
    Cost-to-cost reimbursements and LIBOR-based receivables interest were accepted, with withholding and transfer pricing additions deleted.
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    Discounted cash flow share premium valuation and no-exempt-income rule: additions deleted, with prospective amendment held inapplicable
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    Adequate enquiry bars revision under section 263 where trust advance to a specified person was examined
    June 23, 2026   Case Laws Income Tax
    Cross-examination and corroboration defeat penalty for alleged cash loan based only on third-party statements and loose papers.
    June 23, 2026   Case Laws Income Tax
    Under-reporting penalty and 14A disallowance deleted where the notice was wrongly framed and no exempt income existed
    June 23, 2026   Case Laws Income Tax
    Fair market value under section 50C must reflect existing property condition, not hypothetical development, and statutory valuation steps must be foll...
    June 23, 2026   Case Laws Income Tax
    Search assessment additions require incriminating material; estimated stock and third-party ledger claims failed, while limited profit addition surviv...
    June 23, 2026   Case Laws Income Tax
    Bank tax deductions and depreciation claims upheld as unrealised forex gains and MAT challenges failed entirely
    June 23, 2026   Case Laws Income Tax
    Section 10AA deduction and reassessment scope: partner remuneration omission and unrelated additions were both held unsustainable
    June 23, 2026   Case Laws Income Tax
    Protective addition and commission income fail where cash and profit were owned up by others; seized gold requires verification
    June 23, 2026   Case Laws Income Tax
    ESOP discount deduction and no-exempt-income rule under section 14A supported deletion of tax disallowances.
    June 23, 2026   Case Laws Income Tax
    Reopening after scrutiny assessment fails where recorded reasons rest on a false premise and show non-application of mind
    June 23, 2026   Case Laws Income Tax
    Uncorroborated search material cannot sustain protective additions when seized papers lack corroboration and no fresh evidence emerges.
    June 23, 2026   Case Laws Income Tax
    Section 153C jurisdiction turns on receipt of seized material date, not searched person's search date, for other person assessments.
    June 23, 2026   Case Laws Income Tax
    DSIR-approved R&D deduction and APA-aligned transfer pricing adjustments were limited, while double disallowance was rejected.
    June 23, 2026   Case Laws Income Tax
    Condonation of initial non-compliance with assessment notices bars penalty where later replies are accepted in assessment.
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June 23, 2026   Case Laws FEMA
FERA show-cause notices after repeal were quashed for lack of jurisdiction under the FEMA savings scheme
June 23, 2026   Case Laws GST
Composite show cause notices covering multiple assessment years are unsustainable; separate notices and limitation exclusion follow.
June 23, 2026   Case Laws Income Tax
Advertising contract classification for Google AdWords payments prevailed over technical services treatment, so Section 194C TDS applied.
June 23, 2026   Case Laws Income Tax
Cost-to-cost reimbursements and LIBOR-based receivables interest were accepted, with withholding and transfer pricing additions deleted.
June 23, 2026   Case Laws Income Tax
Discounted cash flow share premium valuation and no-exempt-income rule: additions deleted, with prospective amendment held inapplicable
June 23, 2026   Case Laws Income Tax
Territorial jurisdiction of Assessing Officer: notice by a non-jurisdictional officer held invalid, assessments quashed.
June 23, 2026   Case Laws Income Tax
Adequate enquiry bars revision under section 263 where trust advance to a specified person was examined
June 23, 2026   Case Laws Income Tax
Cross-examination and corroboration defeat penalty for alleged cash loan based only on third-party statements and loose papers.
June 23, 2026   Case Laws Income Tax
Under-reporting penalty and 14A disallowance deleted where the notice was wrongly framed and no exempt income existed
June 23, 2026   Case Laws Income Tax
Fair market value under section 50C must reflect existing property condition, not hypothetical development, and statutory valuation steps must be followed.
June 23, 2026   Case Laws Income Tax
Search assessment additions require incriminating material; estimated stock and third-party ledger claims failed, while limited profit addition survived.
June 23, 2026   Case Laws Income Tax
Bank tax deductions and depreciation claims upheld as unrealised forex gains and MAT challenges failed entirely
June 23, 2026   Case Laws Income Tax
Section 10AA deduction and reassessment scope: partner remuneration omission and unrelated additions were both held unsustainable
June 23, 2026   Case Laws Income Tax
Protective addition and commission income fail where cash and profit were owned up by others; seized gold requires verification
June 23, 2026   Case Laws Income Tax
ESOP discount deduction and no-exempt-income rule under section 14A supported deletion of tax disallowances.
June 23, 2026   Case Laws Income Tax
Reopening after scrutiny assessment fails where recorded reasons rest on a false premise and show non-application of mind
June 23, 2026   Case Laws Income Tax
Uncorroborated search material cannot sustain protective additions when seized papers lack corroboration and no fresh evidence emerges.
June 23, 2026   Case Laws Income Tax
Section 153C jurisdiction turns on receipt of seized material date, not searched person's search date, for other person assessments.
June 23, 2026   Case Laws Income Tax
DSIR-approved R&D deduction and APA-aligned transfer pricing adjustments were limited, while double disallowance was rejected.
June 23, 2026   Case Laws Income Tax
Condonation of initial non-compliance with assessment notices bars penalty where later replies are accepted in assessment.

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Income Tax

Permanent Establishment under Article 5 of the DTAA between...

Appellant Found to Have Permanent Establishment in India Under Article 5 of India-U.S. DTAA Agreement.

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Income Tax November 13, 2013 Case Laws AT
Permanent Establishment under Article 5 of the DTAA between India and U.S.A - Whether Appellant has a Permanent Establishment ('PE') in India under Article 5 of the DTAA between India and U.S.A - held yes - AT
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