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    July 18, 2026   Case LawsIncome Tax
    Genuine hardship in revised-return delays requires pragmatic consideration where consistent relief exists for similarly placed voluntary retirement re...
    July 18, 2026   Case LawsIncome Tax
    Unexplained investment requires reliable evidence; telescoping fails without timing linkage, while fixed-deposit additions exclude maturity accretions...
    July 18, 2026   Case LawsIncome Tax
    Minimum alternate tax does not apply to statutory bodies outside the Companies Act, leaving book-profit disallowance challenge unsustainable.
    July 18, 2026   Case LawsIncome Tax
    Reassessment based on inapplicable share-transaction information fails when disclosed intraday profit does not match the recorded reopening reasons.
    July 18, 2026   Case LawsIncome Tax
    Surplus interest-free funds rebut interest disallowance, while section 14A computations cannot alone increase minimum alternate tax book profit.
    July 18, 2026   Case LawsIncome Tax
    Electronic filing delay in charitable trust audit reporting warranted condonation where genuine hardship arose from clerical omission.
    July 18, 2026   Case LawsIncome Tax
    Market value for captive electricity consumption follows industrial consumer tariffs, supporting profit computation for the power generation deduction...
    July 18, 2026   Case LawsIncome Tax
    Unverifiable purchases warrant only embedded-profit estimation when accepted sales and records show actual goods were procured.
    July 18, 2026   Case LawsIncome Tax
    Reasonable cause for journal-entry loan transfers can protect genuine restructuring transactions from penalties for prescribed loan acceptance modes.
    July 18, 2026   Case LawsIncome Tax
    Commercial nexus of facilitation services supports deduction of commission expenditure against income from other sources.
    July 18, 2026   Case LawsIncome Tax
    Reassessment limitation for pre-2021 assessment years invalidated a belated notice, while unsupported share-sale cash-credit additions were deleted.
    July 18, 2026   Case LawsIncome Tax
    Cash repayment of explained family loans between spouses warranted reasonable cause, requiring deletion of the repayment penalty.
    July 18, 2026   Case LawsIncome Tax
    Business expenditure deductibility covers independent brand promotion and unreimbursed inventory price-drop margin losses where commercially genuine a...
    July 18, 2026   Case LawsIncome Tax
    Pre-2021 reassessment limitation survives amended regime, invalidating notices issued after the former statutory time limit expires.
    July 18, 2026   Case LawsIncome Tax
    Third-party loose sheets require independent corroboration before supporting unexplained investment additions for alleged on-money property purchases.
    July 18, 2026   Case LawsIncome Tax
    BOT annuity rights are not depreciable intangible assets, while project-cost amortisation may follow provisional completion certification.
    July 18, 2026   Case LawsCustoms
    Provisional release of seized imports requires enhanced duty payment, bank guarantee and disclosures while customs adjudication proceeds independently...
    July 18, 2026   Case LawsCustoms
    Strict construction of textile duty exemptions excludes omitted schedule entries, while disclosed import claims cannot trigger extended limitation.
    July 18, 2026   Case LawsCustoms
    Certificate of Origin verification procedures governed preferential customs exemption, rendering denial of treaty benefits and consequential penalty u...
    July 18, 2026   Case LawsCustoms
    In rem liability of a conveyance survives absent owner penalty, while driver penalty for diversion of smuggled goods stands.
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    July 18, 2026   Case Laws Income Tax
    Genuine hardship in revised-return delays requires pragmatic consideration where consistent relief exists for similarly placed voluntary retirement retirees.
    July 18, 2026   Case Laws Income Tax
    Unexplained investment requires reliable evidence; telescoping fails without timing linkage, while fixed-deposit additions exclude maturity accretions.
    July 18, 2026   Case Laws Income Tax
    Minimum alternate tax does not apply to statutory bodies outside the Companies Act, leaving book-profit disallowance challenge unsustainable.
    July 18, 2026   Case Laws Income Tax
    Reassessment based on inapplicable share-transaction information fails when disclosed intraday profit does not match the recorded reopening reasons.
    July 18, 2026   Case Laws Income Tax
    Surplus interest-free funds rebut interest disallowance, while section 14A computations cannot alone increase minimum alternate tax book profit.
    July 18, 2026   Case Laws Income Tax
    Electronic filing delay in charitable trust audit reporting warranted condonation where genuine hardship arose from clerical omission.
    July 18, 2026   Case Laws Income Tax
    Market value for captive electricity consumption follows industrial consumer tariffs, supporting profit computation for the power generation deduction.
    July 18, 2026   Case Laws Income Tax
    Unverifiable purchases warrant only embedded-profit estimation when accepted sales and records show actual goods were procured.
    July 18, 2026   Case Laws Income Tax
    Reasonable cause for journal-entry loan transfers can protect genuine restructuring transactions from penalties for prescribed loan acceptance modes.
    July 18, 2026   Case Laws Income Tax
    Commercial nexus of facilitation services supports deduction of commission expenditure against income from other sources.
    July 18, 2026   Case Laws Income Tax
    Reassessment limitation for pre-2021 assessment years invalidated a belated notice, while unsupported share-sale cash-credit additions were deleted.
    July 18, 2026   Case Laws Income Tax
    Cash repayment of explained family loans between spouses warranted reasonable cause, requiring deletion of the repayment penalty.
    July 18, 2026   Case Laws Income Tax
    Business expenditure deductibility covers independent brand promotion and unreimbursed inventory price-drop margin losses where commercially genuine and verifiable.
    July 18, 2026   Case Laws Income Tax
    Pre-2021 reassessment limitation survives amended regime, invalidating notices issued after the former statutory time limit expires.
    July 18, 2026   Case Laws Income Tax
    Third-party loose sheets require independent corroboration before supporting unexplained investment additions for alleged on-money property purchases.
    July 18, 2026   Case Laws Income Tax
    BOT annuity rights are not depreciable intangible assets, while project-cost amortisation may follow provisional completion certification.
    July 18, 2026   Case Laws Customs
    Provisional release of seized imports requires enhanced duty payment, bank guarantee and disclosures while customs adjudication proceeds independently.
    July 18, 2026   Case Laws Customs
    Strict construction of textile duty exemptions excludes omitted schedule entries, while disclosed import claims cannot trigger extended limitation.
    July 18, 2026   Case Laws Customs
    Certificate of Origin verification procedures governed preferential customs exemption, rendering denial of treaty benefits and consequential penalty unsustainable.
    July 18, 2026   Case Laws Customs
    In rem liability of a conveyance survives absent owner penalty, while driver penalty for diversion of smuggled goods stands.

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      Home› Highlights › Income Tax › 2015 › September, 2015 › This
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      Income Tax

      Indo-UK DTAA - neither under Article 5(2)(k) nor under Article...

      Assessee's Distribution Fee Not Taxable in India Under Indo-UK DTAA; No Permanent Establishment Per Articles 5(2)(k) & 5(4).

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      Income TaxSeptember 19, 2015Case LawsAT
      Indo-UK DTAA - neither under Article 5(2)(k) nor under Article 5(4) read with 5(5), the assessee has a PE in India and, therefore, the distribution fee received by the assessee can not be held to be taxable in India. - AT
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