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    June 22, 2026   Case LawsIncome Tax
    Year-specific satisfaction note required for section 153C jurisdiction; common mechanical note vitiated assessment where seized material lacked nexus
    June 22, 2026   Case LawsIncome Tax
    Consistency in assessee's own case defeats notional interest addition on subsidiary loans; settled view was followed
    June 22, 2026   Case LawsIncome Tax
    Unexplained investment in property: banking trail and parent-funded payment defeated section 69 addition despite no gift deed.
    June 22, 2026   Case LawsIncome Tax
    Surrendered business income cannot be taxed as unexplained income absent an independent source; business treatment affirmed.
    June 22, 2026   Case LawsIncome Tax
    Under-reporting penalty for depreciation disallowance fails where a charitable trust's income remains nil and no tax is payable
    June 22, 2026   Case LawsIncome Tax
    Make available test under India-UK DTAA: managerial business support services were not fees for technical services
    June 22, 2026   Case LawsIncome Tax
    Convertible debentures remain debt until conversion, and pre-conversion interest plus receivable adjustments need fresh transfer pricing review.
    June 22, 2026   Case LawsIncome Tax
    Electronic receipt of DRP directions triggers limitation for final assessment, making a later order time-barred.
    June 22, 2026   Case LawsIncome Tax
    Revenue expenditure and business deduction claims upheld for IPL franchise, website, club and employee costs
    June 22, 2026   Case LawsIncome Tax
    Working capital adjustment, comparable selection and trade receivables interest were revisited in transfer pricing, with key additions deleted and rem...
    June 22, 2026   Case LawsIncome Tax
    Corporate guarantee commission and book profit computation require fact-based allocation and fresh recomputation after Section 14A exclusion
    June 22, 2026   Case LawsCustoms
    Customs classification disputes and show cause notices: writ interference declined, statutory adjudication required, natural justice plea left open.
    June 22, 2026   Case LawsCustoms
    Suspension of container freight station approval remanded after unargued contention, with interim revival of suspension order
    June 22, 2026   Case LawsCustoms
    Strict construction of baggage exclusion preserves tribunal jurisdiction over seized foreign currency disputes before customs clearance
    June 22, 2026   Case LawsIBC
    Writ jurisdiction over pending tribunal proceedings barred when alternative remedies exist; parallel filings treated as abuse of process
    June 22, 2026   Case LawsIBC
    Tentative security interest determination: liquidator's distribution view was not final and remained subject to pending appellate challenge.
    June 22, 2026   Case LawsIBC
    Proof of deposit and insolvency moratorium controlled the repayment claim, leaving only the insolvency process remedy.
    June 22, 2026   Case LawsIBC
    Reasoned adjudication requires consideration of pleadings; unreasoned partial relief order was quashed and remanded for fresh decision.
    June 22, 2026   Case LawsService Tax
    Wrong assessee code and unjust enrichment cannot defeat refund once the service tax levy fails on mutuality grounds.
    June 22, 2026   Case LawsService Tax
    Refund of service tax paid by mistake may survive limitation where tax was not payable, subject to verification.
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    June 22, 2026   Case Laws Income Tax
    Year-specific satisfaction note required for section 153C jurisdiction; common mechanical note vitiated assessment where seized material lacked nexus
    June 22, 2026   Case Laws Income Tax
    Consistency in assessee's own case defeats notional interest addition on subsidiary loans; settled view was followed
    June 22, 2026   Case Laws Income Tax
    Unexplained investment in property: banking trail and parent-funded payment defeated section 69 addition despite no gift deed.
    June 22, 2026   Case Laws Income Tax
    Surrendered business income cannot be taxed as unexplained income absent an independent source; business treatment affirmed.
    June 22, 2026   Case Laws Income Tax
    Under-reporting penalty for depreciation disallowance fails where a charitable trust's income remains nil and no tax is payable
    June 22, 2026   Case Laws Income Tax
    Make available test under India-UK DTAA: managerial business support services were not fees for technical services
    June 22, 2026   Case Laws Income Tax
    Convertible debentures remain debt until conversion, and pre-conversion interest plus receivable adjustments need fresh transfer pricing review.
    June 22, 2026   Case Laws Income Tax
    Electronic receipt of DRP directions triggers limitation for final assessment, making a later order time-barred.
    June 22, 2026   Case Laws Income Tax
    Revenue expenditure and business deduction claims upheld for IPL franchise, website, club and employee costs
    June 22, 2026   Case Laws Income Tax
    Working capital adjustment, comparable selection and trade receivables interest were revisited in transfer pricing, with key additions deleted and remitted.
    June 22, 2026   Case Laws Income Tax
    Corporate guarantee commission and book profit computation require fact-based allocation and fresh recomputation after Section 14A exclusion
    June 22, 2026   Case Laws Customs
    Customs classification disputes and show cause notices: writ interference declined, statutory adjudication required, natural justice plea left open.
    June 22, 2026   Case Laws Customs
    Suspension of container freight station approval remanded after unargued contention, with interim revival of suspension order
    June 22, 2026   Case Laws Customs
    Strict construction of baggage exclusion preserves tribunal jurisdiction over seized foreign currency disputes before customs clearance
    June 22, 2026   Case Laws IBC
    Writ jurisdiction over pending tribunal proceedings barred when alternative remedies exist; parallel filings treated as abuse of process
    June 22, 2026   Case Laws IBC
    Tentative security interest determination: liquidator's distribution view was not final and remained subject to pending appellate challenge.
    June 22, 2026   Case Laws IBC
    Proof of deposit and insolvency moratorium controlled the repayment claim, leaving only the insolvency process remedy.
    June 22, 2026   Case Laws IBC
    Reasoned adjudication requires consideration of pleadings; unreasoned partial relief order was quashed and remanded for fresh decision.
    June 22, 2026   Case Laws Service Tax
    Wrong assessee code and unjust enrichment cannot defeat refund once the service tax levy fails on mutuality grounds.
    June 22, 2026   Case Laws Service Tax
    Refund of service tax paid by mistake may survive limitation where tax was not payable, subject to verification.

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      Home› Highlights › Income Tax › 2014 › April, 2014 › This
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      Income Tax

      Sale of software and maintenance services – Royalty - The right t...

      Software Sale and Backup Rights: No Royalty When Backup is for Temporary Protection Only, No Copyright Transfer Involved.

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      Income TaxApril 12, 2014Case LawsAT
      Sale of software and maintenance services – Royalty - The right to make a backup copy purely as a temporary protection against loss, destruction or damage does not amount to acquiring a copyright in the software - AT
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