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    April 9, 2026   Case Laws Income Tax
    Income recognition, energy tax, accrued liability and computer depreciation issues were all resolved against the Department.
    April 9, 2026   Case Laws Income Tax
    Procedural lapse cannot defeat concessional tax benefit where eligibility is undisputed and delay is short and bona fide.
    April 9, 2026   Case Laws Income Tax
    Section 170A limits post-amalgamation assessment to modification only where the assessment was already completed.
    April 9, 2026   Case Laws Income Tax
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    April 9, 2026   Case Laws Income Tax
    Bona fide treaty relief claim defeats penalty where income was disclosed and no concealment or inaccurate particulars were proved.
    April 9, 2026   Case Laws Income Tax
    Prior-period expenditure may be considered in the correct assessment year when genuineness is undisputed and revised computation is filed.
    April 9, 2026   Case Laws Income Tax
    Commercial expediency and rectification limits upheld as interest deduction was allowed and no apparent mistake was found.
    April 9, 2026   Case Laws Income Tax
    Reassessment and fee-for-technical-services classification: reopening upheld, but certain reimbursements and mobilization charges fell outside treaty ...
    April 9, 2026   Case Laws Income Tax
    Set-off of unabsorbed depreciation against unaccounted stock addition allowed; later restrictions under Sections 79A and 115BBE did not apply.
    April 9, 2026   Case Laws Income Tax
    Unexplained expenditure on purchases cannot rest on suspicion where books, stock records and bank evidence remain unrebutted.
    April 9, 2026   Case Laws Income Tax
    Charitable registration operates prospectively under the amended scheme, with retrospective benefit unavailable absent pending proceedings.
    April 9, 2026   Case Laws Income Tax
    Section 80P deduction for co-operative societies remains available despite nominal members and housing society status, with limited interest income tr...
    April 9, 2026   Case Laws Income Tax
    Overriding title, rectification, and bad debt claims: Tribunal rejects DICGC diversion but allows set-off dispute and write-off relief.
    April 9, 2026   Case Laws Income Tax
    Invalid reassessment approval and wrong post-search procedure led to quashing, with relief on unexplained investment and telescoping.
    April 9, 2026   Case Laws Income Tax
    Penalty under sections 271D and 271(1)(c) deleted where cheque receipts and bona fide loss claim defeated alleged concealment.
    April 9, 2026   Case Laws Income Tax
    Separate taxable entity principle upheld for a partnership firm; pre-existence interest expenditure remained disallowed.
    April 9, 2026   Case Laws Customs
    Provisional bank account attachment lapses on expiry unless extended in time, restoring the right to operate accounts.
    April 9, 2026   Case Laws Customs
    NFEP shortfall does not create duty on installed EOU capital goods; penalty also falls with the unsustainable demand.
    April 9, 2026   Case Laws Customs
    Retail sale price redetermination cannot support differential CVD recovery for post-import relabelling of mobile phones.
    April 9, 2026   Case Laws Customs
    Export valuation evidence failed where statements lacked corroboration and electronic records were inadmissible under customs law.
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April 9, 2026   Case Laws Income Tax
Income recognition, energy tax, accrued liability and computer depreciation issues were all resolved against the Department.
April 9, 2026   Case Laws Income Tax
Procedural lapse cannot defeat concessional tax benefit where eligibility is undisputed and delay is short and bona fide.
April 9, 2026   Case Laws Income Tax
Section 170A limits post-amalgamation assessment to modification only where the assessment was already completed.
April 9, 2026   Case Laws Income Tax
Book profit treatment for bad debts and directory audit-report filing shaped the outcome on deduction claims.
April 9, 2026   Case Laws Income Tax
Bona fide treaty relief claim defeats penalty where income was disclosed and no concealment or inaccurate particulars were proved.
April 9, 2026   Case Laws Income Tax
Prior-period expenditure may be considered in the correct assessment year when genuineness is undisputed and revised computation is filed.
April 9, 2026   Case Laws Income Tax
Commercial expediency and rectification limits upheld as interest deduction was allowed and no apparent mistake was found.
April 9, 2026   Case Laws Income Tax
Reassessment and fee-for-technical-services classification: reopening upheld, but certain reimbursements and mobilization charges fell outside treaty taxation.
April 9, 2026   Case Laws Income Tax
Set-off of unabsorbed depreciation against unaccounted stock addition allowed; later restrictions under Sections 79A and 115BBE did not apply.
April 9, 2026   Case Laws Income Tax
Unexplained expenditure on purchases cannot rest on suspicion where books, stock records and bank evidence remain unrebutted.
April 9, 2026   Case Laws Income Tax
Charitable registration operates prospectively under the amended scheme, with retrospective benefit unavailable absent pending proceedings.
April 9, 2026   Case Laws Income Tax
Section 80P deduction for co-operative societies remains available despite nominal members and housing society status, with limited interest income treatment
April 9, 2026   Case Laws Income Tax
Overriding title, rectification, and bad debt claims: Tribunal rejects DICGC diversion but allows set-off dispute and write-off relief.
April 9, 2026   Case Laws Income Tax
Invalid reassessment approval and wrong post-search procedure led to quashing, with relief on unexplained investment and telescoping.
April 9, 2026   Case Laws Income Tax
Penalty under sections 271D and 271(1)(c) deleted where cheque receipts and bona fide loss claim defeated alleged concealment.
April 9, 2026   Case Laws Income Tax
Separate taxable entity principle upheld for a partnership firm; pre-existence interest expenditure remained disallowed.
April 9, 2026   Case Laws Customs
Provisional bank account attachment lapses on expiry unless extended in time, restoring the right to operate accounts.
April 9, 2026   Case Laws Customs
NFEP shortfall does not create duty on installed EOU capital goods; penalty also falls with the unsustainable demand.
April 9, 2026   Case Laws Customs
Retail sale price redetermination cannot support differential CVD recovery for post-import relabelling of mobile phones.
April 9, 2026   Case Laws Customs
Export valuation evidence failed where statements lacked corroboration and electronic records were inadmissible under customs law.

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Income Tax

The payments received by the applicant from the distributor for...

Software Sales Payments Classified as Royalties; TDS Deduction Required Under IT Act Section 9(1)(vi) and DTAA Article 12.

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Income Tax August 5, 2015 Case Laws AAR
The payments received by the applicant from the distributor for sale of the software product are in the nature of royalty both within the meaning of section 9(1)(vi) of the IT Act and within the meaning of Article 12 of the DTAA - TDS required to be deducted u/s 195 - AAR
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