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    October 21, 2026   Case Laws Income Tax
    Sufficient Cause for Delay Requires a Pleaded Explanation; Unexplained Inaction Leaves Revenue Appeal Time-Barred Under Limitation Law
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    Angadia cash-transit receipts are taxable only to the extent of embedded commission, rather than as unexplained principal funds.
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    Revision jurisdiction cannot create a fresh foundation for independent cash-transaction penalty proceedings after a completed assessment.
    October 21, 2026   Case Laws Income Tax
    Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
    October 21, 2026   Case Laws Income Tax
    Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
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    Final assessment limitation follows DRP-specific timelines when the draft order is timely, despite expiry of general assessment limits.
    October 21, 2026   Case Laws Income Tax
    Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
    October 21, 2026   Case Laws Income Tax
    Accommodation-entry loan additions require evidence beyond generic third-party allegations, while interest disallowance needs proof of actual incurren...
    October 21, 2026   Case Laws Income Tax
    Comparable uncontrolled price method requires actual uncontrolled transactions, resulting in deletion of unsupported related-party loan interest adjus...
    October 21, 2026   Case Laws Income Tax
    Limitation for section 271D penalties requires a timely order, making orders beyond the statutory period invalid.
    October 21, 2026   Case Laws Income Tax
    Service of reassessment notice remains a jurisdictional precondition; participation after inquiry notice cannot cure non-service.
    October 21, 2026   Case Laws Income Tax
    Reassessment based on third-party information upheld, while profit element in fictitious purchases remains subject to estimated disallowance.
    October 21, 2026   Case Laws Income Tax
    Notice under section 143(2) is mandatory for section 153C assessments, and its complete absence invalidates assessments.
    October 21, 2026   Case Laws Income Tax
    Search assessment jurisdiction requires a valid assessment block, asset-linked escaped income, incriminating material, and timely completion.
    October 21, 2026   Case Laws Income Tax
    Royalty benchmarking requires reliable uncontrolled comparables, supporting TNMM aggregation where technical know-how payments are tied to manufacturi...
    October 21, 2026   Case Laws Income Tax
    Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
    October 21, 2026   Case Laws Income Tax
    Year-end accruals under consistent accounting remain deductible; duplicate taxation, invalid remands, and uninitiated penalties cannot stand.
    October 21, 2026   Case Laws Customs
    Sufficient cause for delayed Customs appeals excludes unexplained administrative inaction and unsupported blame placed on former counsel.
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October 21, 2026   Case Laws Income Tax
Sufficient Cause for Delay Requires a Pleaded Explanation; Unexplained Inaction Leaves Revenue Appeal Time-Barred Under Limitation Law
October 21, 2026   Case Laws Income Tax
Angadia cash-transit receipts are taxable only to the extent of embedded commission, rather than as unexplained principal funds.
October 21, 2026   Case Laws Income Tax
Reassessment on Borrowed Satisfaction Fails When Recorded Share Transactions Were Already Examined and Accepted in Scrutiny
October 21, 2026   Case Laws Income Tax
Leasehold land rights under Section 56(2)(x): purchase excluded from income-tax additions on the facts presented.
October 21, 2026   Case Laws Income Tax
Revision jurisdiction cannot create a fresh foundation for independent cash-transaction penalty proceedings after a completed assessment.
October 21, 2026   Case Laws Income Tax
Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier assessment years.
October 21, 2026   Case Laws Income Tax
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available.
October 21, 2026   Case Laws Income Tax
Final assessment limitation follows DRP-specific timelines when the draft order is timely, despite expiry of general assessment limits.
October 21, 2026   Case Laws Income Tax
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unestablished.
October 21, 2026   Case Laws Income Tax
Accommodation-entry loan additions require evidence beyond generic third-party allegations, while interest disallowance needs proof of actual incurrence.
October 21, 2026   Case Laws Income Tax
Comparable uncontrolled price method requires actual uncontrolled transactions, resulting in deletion of unsupported related-party loan interest adjustment.
October 21, 2026   Case Laws Income Tax
Limitation for section 271D penalties requires a timely order, making orders beyond the statutory period invalid.
October 21, 2026   Case Laws Income Tax
Service of reassessment notice remains a jurisdictional precondition; participation after inquiry notice cannot cure non-service.
October 21, 2026   Case Laws Income Tax
Reassessment based on third-party information upheld, while profit element in fictitious purchases remains subject to estimated disallowance.
October 21, 2026   Case Laws Income Tax
Notice under section 143(2) is mandatory for section 153C assessments, and its complete absence invalidates assessments.
October 21, 2026   Case Laws Income Tax
Search assessment jurisdiction requires a valid assessment block, asset-linked escaped income, incriminating material, and timely completion.
October 21, 2026   Case Laws Income Tax
Royalty benchmarking requires reliable uncontrolled comparables, supporting TNMM aggregation where technical know-how payments are tied to manufacturing operations.
October 21, 2026   Case Laws Income Tax
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and transfer-pricing principles.
October 21, 2026   Case Laws Income Tax
Year-end accruals under consistent accounting remain deductible; duplicate taxation, invalid remands, and uninitiated penalties cannot stand.
October 21, 2026   Case Laws Customs
Sufficient cause for delayed Customs appeals excludes unexplained administrative inaction and unsupported blame placed on former counsel.

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Home › Highlights › Income Tax › 2018 › December, 2018 › This
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Income Tax

Accrual of Income in India - assessee as a non-resident company...

License Fees Not Classified as 'Royalty' Under India-Canada DTAA; No Tax for Non-Resident Company.

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Income Tax December 22, 2018 Case Laws AT
Accrual of Income in India - assessee as a non-resident company which received licence fees in terms of "Membership and Technology Transfer Agreement" - the receipt cannot be characterized as ‘royalty’ and, therefore, the same is outside the purview of taxation in view of India-Canada DTAA.
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