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October 19, 2026   Case Laws Income Tax
Transfer-pricing valuation requires associated-enterprise status and a prescribed method; research and software deductions depend on business nexus.
October 19, 2026   Case Laws Income Tax
Under-reporting on a first reassessment return attracts penalty, while enhanced misreporting penalty requires proof of a statutory misreporting category.
October 19, 2026   Case Laws Income Tax
Reassessment approval requires prescribed authority, and failure to issue mandatory scrutiny notice invalidates the resulting assessment proceedings.
October 19, 2026   Case Laws Income Tax
Section 68 evidence standards require deletion of share capital and loan additions when identity, creditworthiness and genuineness are established.
October 19, 2026   Case Laws Income Tax
Bad-debt write-offs and related-party rent: deductions sustained where receivables were written off and no market-value excess was shown.
October 19, 2026   Case Laws Income Tax
Presumptive taxation classification supports business treatment for global ranking support services over professional income estimation.
October 19, 2026   Case Laws Income Tax
Taxability of non-resident commissions governs TDS, while a missing residency certificate alone cannot create Indian tax liability.
October 19, 2026   Case Laws Income Tax
Genuineness of charitable activities requires transparent donation sources and identifiable public beneficiaries for registration renewal.
October 19, 2026   Case Laws Income Tax
Reasonable cause for cash property advances can avert penalties despite specified-sum restrictions and disclosure requirements.
October 19, 2026   Case Laws Income Tax
Political contribution genuineness governs deduction where accommodation-entry evidence defeats banking records and makes penalty challenge premature.
October 19, 2026   Case Laws Income Tax
Profit-element additions for non-genuine metal purchases apply where related sales are undisputed, reducing the purchase-based addition.
October 19, 2026   Case Laws Income Tax
Residual profit split method bars a second entity-level margin adjustment for the same integrated services transaction.
October 19, 2026   Case Laws Income Tax
Construction Cost Evidence for Flat Sales Requires Capital-Gains Recalculation While Reassessment Remains Valid After Proper Notice
October 19, 2026   Case Laws Income Tax
Form 26AS evidence requires successor-entity accounting verification after business transfer, while invoice-supported related-party advertising expenditure remains allowable.
October 19, 2026   Case Laws Customs
Speaking-order requirements protect importers where reassessment changes classification and value without proven grounds or procedural fairness.
October 19, 2026   Case Laws Customs
Intermediary liability for concealed imports requires proof of knowledge or participation; mere introductions cannot support abetment penalties.
October 19, 2026   Case Laws IBC
CIRP appeal authority: Suspended directors cannot cure an incompetent corporate debtor appeal through amendment after limitation expires.
October 19, 2026   Case Laws Money Laundering
Proceeds-of-crime nexus remains essential before later asset dealings can support money-laundering allegations and continued pre-trial detention.
October 19, 2026   Case Laws Money Laundering
PMLA anticipatory bail conditions require personal cooperation and cannot be met where proceeds-of-crime investigation remains ongoing.
October 19, 2026   Case Laws Money Laundering
PMLA attachment preservation allows housing redevelopment while replacement flat and all related accruals remain subject to attachment.

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Home › Highlights › Income Tax › 2019 › May, 2019 › This
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Income Tax

TPA - MAM selection - CUP or TNMM - if the intra AE transactions...

Court Rejects CUP Method in Transfer Pricing Case, Suggests TNMM Due to Data Insufficiency and Transaction Differences.

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Income Tax May 2, 2019 Case Laws AT
TPA - MAM selection - CUP or TNMM - if the intra AE transactions were fundamentally different in character in economic circumstances and contractual terms then these cannot be compared with the independent transactions entered into by the assessee - the availability, coverage and reliability of data necessary for application of the method - CUP rejected
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