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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.
June 9, 2026   Case Laws Income Tax
Revisional power under section 264 cannot worsen assessee's position; cash deposits explained from past salary savings.
June 9, 2026   Case Laws Income Tax
Fair market value of surrendered tenancy rights can determine cost of acquisition for redeveloped property gains

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Income Tax

Attribution of profits out of the sales made by the head office...

India Branch's 20% Gross Profit Rate Unjustified; TPO Accepts Head Office's 8.81% Rate as Reasonable.

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Income Tax October 22, 2015 Case Laws AT
Attribution of profits out of the sales made by the head office - the TPO has accepted the gross profit rate declared at 8.81%. In such a situation, acceptance of gross profit attribution of India Branch @ 20% does not inbspire confidence. - AT
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