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    August 20, 2026   Case LawsIncome Tax
    Transfer-pricing method selection remains factual where TNMM is rule-compliant, leaving no substantial question of law for review.
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    August 20, 2026   Case LawsIncome Tax
    Faceless reassessment jurisdiction remains valid, while ex parte additions require fresh appellate review where natural justice demands hearing.
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    Co-operative deduction eligibility excludes refund and commercial-bank interest, while qualifying co-operative investments require entity-wise verific...
    August 20, 2026   Case LawsIncome Tax
    Enhanced tax rate on surrendered unexplained income applies prospectively, while cash-deposit telescoping requires verification of available surrender...
    August 20, 2026   Case LawsIncome Tax
    Bad-debt deductions for written-off commodity receivables were allowed, while windmill-profit expense allocation required fresh factual examination.
    August 20, 2026   Case LawsIncome Tax
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    August 20, 2026   Case LawsIncome Tax
    Rejection of unreliable liquor-trade books justified profit estimation and separate taxation of omitted advertisement-display business receipts.
    August 20, 2026   Case LawsIncome Tax
    Specific penalty charges under section 270A are mandatory; vague notices for under-reporting or misreporting cannot sustain penalties.
    August 20, 2026   Case LawsIncome Tax
    Actual redemption consideration governs preference-share capital gains where no deeming rule permits substitution with equity-share valuation.
    August 20, 2026   Case LawsIncome Tax
    Non-cash share consideration escapes share-premium taxation, while bad debts and unsupported prior-period claims receive differing treatment.
    August 20, 2026   Case LawsIncome Tax
    Transfer pricing tolerance rules remove adjustments where software and advertising service prices fall within prescribed ranges.
    August 20, 2026   Case LawsCustoms
    Re-import exemption excludes FTWZ-to-DTA clearance when petroleum equipment returns under a fresh essentiality certificate for a new contract.
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    August 20, 2026   Case Laws Income Tax
    Transfer-pricing method selection remains factual where TNMM is rule-compliant, leaving no substantial question of law for review.
    August 20, 2026   Case Laws Income Tax
    Reopening after four years fails where audit objections merely trigger re-examination of records already assessed without fresh tangible material.
    August 20, 2026   Case Laws Income Tax
    TDS credit for actual deduction cannot be denied solely because the deductor failed to deposit or report tax.
    August 20, 2026   Case Laws Income Tax
    Depreciation on acquired brand-name and distribution rights is allowable as business or commercial intangible assets under Section 32.
    August 20, 2026   Case Laws Income Tax
    Ind AS and ICDS tax computation principles prevent taxation of notional income and unsupported double disallowances.
    August 20, 2026   Case Laws Income Tax
    Capital gains on transferable development rights apply where surrendered land provides an ascertainable acquisition cost for the rights.
    August 20, 2026   Case Laws Income Tax
    Dividend distribution tax treaty-rate claims await Supreme Court guidance before fresh adjudication of India-Netherlands DTAA applicability.
    August 20, 2026   Case Laws Income Tax
    Reasoned adjudication of reassessment jurisdictional objections must precede merits review where foundational defects may invalidate the reassessment.
    August 20, 2026   Case Laws Income Tax
    Concessional corporate tax rate applies despite an incorrect return provision reference where turnover eligibility is otherwise satisfied.
    August 20, 2026   Case Laws Income Tax
    Faceless reassessment jurisdiction remains valid, while ex parte additions require fresh appellate review where natural justice demands hearing.
    August 20, 2026   Case Laws Income Tax
    Co-operative deduction eligibility excludes refund and commercial-bank interest, while qualifying co-operative investments require entity-wise verification.
    August 20, 2026   Case Laws Income Tax
    Enhanced tax rate on surrendered unexplained income applies prospectively, while cash-deposit telescoping requires verification of available surrendered cash.
    August 20, 2026   Case Laws Income Tax
    Bad-debt deductions for written-off commodity receivables were allowed, while windmill-profit expense allocation required fresh factual examination.
    August 20, 2026   Case Laws Income Tax
    Foreign-leg travel reimbursement: binding interim restraint prevented retrospective employer default and eliminated consequential tax-deduction penalty.
    August 20, 2026   Case Laws Income Tax
    Rejection of unreliable liquor-trade books justified profit estimation and separate taxation of omitted advertisement-display business receipts.
    August 20, 2026   Case Laws Income Tax
    Specific penalty charges under section 270A are mandatory; vague notices for under-reporting or misreporting cannot sustain penalties.
    August 20, 2026   Case Laws Income Tax
    Actual redemption consideration governs preference-share capital gains where no deeming rule permits substitution with equity-share valuation.
    August 20, 2026   Case Laws Income Tax
    Non-cash share consideration escapes share-premium taxation, while bad debts and unsupported prior-period claims receive differing treatment.
    August 20, 2026   Case Laws Income Tax
    Transfer pricing tolerance rules remove adjustments where software and advertising service prices fall within prescribed ranges.
    August 20, 2026   Case Laws Customs
    Re-import exemption excludes FTWZ-to-DTA clearance when petroleum equipment returns under a fresh essentiality certificate for a new contract.

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      Home› Highlights › Income Tax › 2016 › June, 2016 › This
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      Income Tax

      TDS u/s 195 - assessee purchased software from two nonresidents...

      Software Purchase from Nonresidents Not a Royalty; No Withholding Tax or Disallowance u/ss 40(a)(i) and 195.

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      Income TaxJune 24, 2016Case LawsAT
      TDS u/s 195 - assessee purchased software from two nonresidents companies - Purchase of software is not in the nature of Royalty and no disallowance u/s.40(a)(i) of the Act is warranted. - AT
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