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    October 27, 2026   Case Laws Income Tax
    TNMM Segmentation Limits Transfer-Pricing Adjustments to Associated-Enterprise Transactions and Requires Turnover-Based Comparable Selection for IT Se...
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    Transfer-pricing documentation penalty cannot survive where the underlying adjustment is deleted, and the Revenue challenge fails on consistent facts.
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    Rectification appeal limitation runs from refusal order, while contingent-liability disclosures cannot justify disallowing unclaimed deductions.
    October 27, 2026   Case Laws Income Tax
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    October 27, 2026   Case Laws Income Tax
    Section 43CB excludes self-developed projects undertaken and sold at the developer's own commercial risk, preserving project-completion accounting.
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    Section 54G relief in MAT computation remains available despite an omitted MAT claim and a return filed within extended time.
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    Rule 46A additional evidence requires merits-based review, while unfinalised penalty challenges remain premature and interest is consequential.
    October 27, 2026   Case Laws Income Tax
    Transfer-pricing references require actual non-disclosure in Form 3CEB; reported CCD interest cannot support a consequential adjustment.
    October 27, 2026   Case Laws Income Tax
    TNMM functional comparability permits revising initial comparable selections, excluding manufacturers from trader benchmarking and recalculating arm's...
    October 27, 2026   Case Laws Income Tax
    Arm's length interest on rupee NCDs requires PLR comparability, rejecting unsupported EBLR benchmarks for fixed-rate instruments.
    October 27, 2026   Case Laws Income Tax
    Co-terminus appellate powers require full verification before deleting TDS disallowances for alleged non-deduction of tax on freight-forwarding paymen...
    October 27, 2026   Case Laws Benami Property
    Benami cash routing through third-party accounts can support attachment, limited after tax payments and prescribed bond deposits.
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    MRP/RSP valuation applied to packaged educational software lacking the mandatory non-retail-sale declaration, sustaining differential duty and penalti...
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October 27, 2026   Case Laws Income Tax
TNMM Segmentation Limits Transfer-Pricing Adjustments to Associated-Enterprise Transactions and Requires Turnover-Based Comparable Selection for IT Services
October 27, 2026   Case Laws Income Tax
Related-party transaction filters and functional differences require exclusion of unreliable TNMM comparables in contact-centre service benchmarking.
October 27, 2026   Case Laws Income Tax
Transfer-pricing documentation penalty cannot survive where the underlying adjustment is deleted, and the Revenue challenge fails on consistent facts.
October 27, 2026   Case Laws Income Tax
Compulsorily convertible debentures remain debt before conversion, barring nil transfer-pricing interest adjustments and related disallowance.
October 27, 2026   Case Laws Income Tax
Internal TNMM supports deletion of freight-forwarding adjustments where comparable non-AE transactions are separately identifiable and materially similar.
October 27, 2026   Case Laws Income Tax
Cloud Application and IT Support Receipts Fail Royalty and Technical Service Tests Under the India-Netherlands Treaty
October 27, 2026   Case Laws Income Tax
Rectification appeal limitation runs from refusal order, while contingent-liability disclosures cannot justify disallowing unclaimed deductions.
October 27, 2026   Case Laws Income Tax
Arm's-length range treatment protects royalty payments within range, while evidence-based intra-group services cannot receive a nil valuation.
October 27, 2026   Case Laws Income Tax
Composite residential houses can qualify for Section 54F despite separate flat registrations, subject to proof of functional interconnection.
October 27, 2026   Case Laws Income Tax
Section 43CB excludes self-developed projects undertaken and sold at the developer's own commercial risk, preserving project-completion accounting.
October 27, 2026   Case Laws Income Tax
Section 54G relief in MAT computation remains available despite an omitted MAT claim and a return filed within extended time.
October 27, 2026   Case Laws Income Tax
Rule 46A additional evidence requires merits-based review, while unfinalised penalty challenges remain premature and interest is consequential.
October 27, 2026   Case Laws Income Tax
Transfer-pricing references require actual non-disclosure in Form 3CEB; reported CCD interest cannot support a consequential adjustment.
October 27, 2026   Case Laws Income Tax
TNMM functional comparability permits revising initial comparable selections, excluding manufacturers from trader benchmarking and recalculating arm's length margins.
October 27, 2026   Case Laws Income Tax
Arm's length interest on rupee NCDs requires PLR comparability, rejecting unsupported EBLR benchmarks for fixed-rate instruments.
October 27, 2026   Case Laws Income Tax
Co-terminus appellate powers require full verification before deleting TDS disallowances for alleged non-deduction of tax on freight-forwarding payments.
October 27, 2026   Case Laws Benami Property
Benami cash routing through third-party accounts can support attachment, limited after tax payments and prescribed bond deposits.
October 27, 2026   Case Laws Customs
MRP/RSP valuation applied to packaged educational software lacking the mandatory non-retail-sale declaration, sustaining differential duty and penalties.
October 27, 2026   Case Laws Customs
Customs valuation safeguards bar NIDB-based enhancement without disclosed comparable-import data and evidence of deliberate misdeclaration.
October 27, 2026   Case Laws Customs
Transferable DFIA exemptions cover generic SION inputs, while Public Notice-only caps and actual-user restrictions cannot deny benefits.

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GST

Before AAR, the following question was raised: I would like to...

AAR advises using interpretative rules to determine correct HSN code for billing mixed materials with one primary component.

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GST May 8, 2018 Case Laws AAR
Before AAR, the following question was raised: I would like to know if there is a combination of different materials and about 75% (value terms) is getting used of any one Raw Material, under which HSN should we make bill? - AAR advised the applicant to understand the interpretative Rules and determine the classification accordingly.
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