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    June 9, 2026   Case Laws Income Tax
    Decretal interest as judgment debt cannot be subjected to TDS deduction by the judgment debtor absent decree authorisation.
    June 9, 2026   Case Laws Income Tax
    Compensatory interest for wrongful retention of seized KVPs and IVPs allowed until release, with simple interest on arrears.
    June 9, 2026   Case Laws Income Tax
    Co-operative bank TDS exemption turned on binding CBDT note, while the restrictive proviso survived constitutional challenge.
    June 9, 2026   Case Laws Income Tax
    Black Money Act limitation and TOLA extensions: assessment quashed as time-barred because the notifications did not apply.
    June 9, 2026   Case Laws Income Tax
    Royalty and FIS/FTS treatment of database recharge and seconded employee reimbursements under India-USA DTAA held non-taxable
    June 9, 2026   Case Laws Income Tax
    Article 8 shipping receipts from feeder vessels and slot hire held covered by the DTAA, not separately taxed.
    June 9, 2026   Case Laws Income Tax
    Arrears of superannuation fund perquisites qualify for salary relief, and Rule 21A applies to the claim.
    June 9, 2026   Case Laws Income Tax
    Burden of proof in penalty cases defeats cash-loan penalties based only on third-party seized papers
    June 9, 2026   Case Laws Income Tax
    Royalty and management support service adjustments fail where costs were recovered and aggregated TNMM benchmarking applied.
    June 9, 2026   Case Laws Income Tax
    Transfer pricing adjustments remanded for fresh review of intra-group services, sensor assembling method and comparables analysis
    June 9, 2026   Case Laws Income Tax
    Foreign asset disclosure in a substituted return can defeat penalty for an earlier omission when assessment accepts it.
    June 9, 2026   Case Laws Income Tax
    Comparability filters in TNMM require upfront R&D screening and broadly similar turnover scales for software services.
    June 9, 2026   Case Laws Income Tax
    Functional comparability in wholesale auto-component trading excludes retail and after-sales comparables, deleting transfer pricing adjustments
    June 9, 2026   Case Laws Income Tax
    Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
    June 9, 2026   Case Laws Income Tax
    Pass-through LLC self-dealing defeats transfer pricing adjustment; linked receivables and profit recomputation were also deleted.
    June 9, 2026   Case Laws Income Tax
    Transfer pricing comparability: predominantly manufacturing comparables were excluded, and IT support charges were not fixed at nil.
    June 9, 2026   Case Laws Income Tax
    Substantial compliance in transfer pricing documentation defeats penalty for diamond trade record shortfall where arm's length pricing stood accepted
    June 9, 2026   Case Laws Income Tax
    Double taxation through rectification was impermissible where income already shown under proper heads was added again to business income.
    June 9, 2026   Case Laws Income Tax
    Bona fide return error defeats misreporting penalty where no specific statutory clause is identified in assessment.
    June 9, 2026   Case Laws Income Tax
    Interest computation in return processing restored for fresh factual verification and de novo adjudication.
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June 9, 2026   Case Laws Income Tax
Decretal interest as judgment debt cannot be subjected to TDS deduction by the judgment debtor absent decree authorisation.
June 9, 2026   Case Laws Income Tax
Compensatory interest for wrongful retention of seized KVPs and IVPs allowed until release, with simple interest on arrears.
June 9, 2026   Case Laws Income Tax
Co-operative bank TDS exemption turned on binding CBDT note, while the restrictive proviso survived constitutional challenge.
June 9, 2026   Case Laws Income Tax
Black Money Act limitation and TOLA extensions: assessment quashed as time-barred because the notifications did not apply.
June 9, 2026   Case Laws Income Tax
Royalty and FIS/FTS treatment of database recharge and seconded employee reimbursements under India-USA DTAA held non-taxable
June 9, 2026   Case Laws Income Tax
Article 8 shipping receipts from feeder vessels and slot hire held covered by the DTAA, not separately taxed.
June 9, 2026   Case Laws Income Tax
Arrears of superannuation fund perquisites qualify for salary relief, and Rule 21A applies to the claim.
June 9, 2026   Case Laws Income Tax
Burden of proof in penalty cases defeats cash-loan penalties based only on third-party seized papers
June 9, 2026   Case Laws Income Tax
Royalty and management support service adjustments fail where costs were recovered and aggregated TNMM benchmarking applied.
June 9, 2026   Case Laws Income Tax
Transfer pricing adjustments remanded for fresh review of intra-group services, sensor assembling method and comparables analysis
June 9, 2026   Case Laws Income Tax
Foreign asset disclosure in a substituted return can defeat penalty for an earlier omission when assessment accepts it.
June 9, 2026   Case Laws Income Tax
Comparability filters in TNMM require upfront R&D screening and broadly similar turnover scales for software services.
June 9, 2026   Case Laws Income Tax
Functional comparability in wholesale auto-component trading excludes retail and after-sales comparables, deleting transfer pricing adjustments
June 9, 2026   Case Laws Income Tax
Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim remanded.
June 9, 2026   Case Laws Income Tax
Pass-through LLC self-dealing defeats transfer pricing adjustment; linked receivables and profit recomputation were also deleted.
June 9, 2026   Case Laws Income Tax
Transfer pricing comparability: predominantly manufacturing comparables were excluded, and IT support charges were not fixed at nil.
June 9, 2026   Case Laws Income Tax
Substantial compliance in transfer pricing documentation defeats penalty for diamond trade record shortfall where arm's length pricing stood accepted
June 9, 2026   Case Laws Income Tax
Double taxation through rectification was impermissible where income already shown under proper heads was added again to business income.
June 9, 2026   Case Laws Income Tax
Bona fide return error defeats misreporting penalty where no specific statutory clause is identified in assessment.
June 9, 2026   Case Laws Income Tax
Interest computation in return processing restored for fresh factual verification and de novo adjudication.

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Income Tax

Transfer u/s 2(47) - Exemption u/s 47(xiii) - partnership firm...

Land Value as Loan Denied Exemption u/s 47(xiii) in Partnership to Company Transfer Case.

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Income Tax April 16, 2014 Case Laws AT
Transfer u/s 2(47) - Exemption u/s 47(xiii) - partnership firm succeeded by a private limited company - Treating value of land as loan in hands of company amounts to an indirect transfer of property to the partners - exemption denied - AT
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Acts Income Tax
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