Just a moment...

⚠ ✕
❮ Top
☎ Help
☰
×

By creating an account you can:

Logo TaxTMI
Keyword Search :
AI Tools : New
Ask tax questions in natural language. Powered by AI trained on the TaxTMI legal database. Use AI Tools ➞
Call Us / Help / Feedback✕

Contact Us At :

✉ E-mail: [email protected]

✆ Call / WhatsApp at: +91 99117 96707

For more information, Check Contact Us

FAQs :

To know Frequently Asked Questions, Check FAQs

Most Asked Video Tutorials :

For more tutorials, Check Video Tutorials

Submit Feedback/Suggestion :

Email :
Please provide your email address so we can follow up on your feedback.
Category :
Description :
Min 15 characters 0/2000
Make Most of Text Search ✕
  1. Checkout this video tutorial: How to search effectively on TaxTMI.
  2. Put words in double quotes for exact word search, eg: "income tax"
  3. Avoid noise words such as : 'and, of, the, a'
  4. Sort by Relevance to get the most relevant document.
  5. Press Enter to add multiple terms/multiple phrases, and then click on Search to Search.
    6. Text Search
  6. The system will try to fetch results that contains ALL your words.
  7. Once you add keywords, you'll see a new 'Search In' filter that makes your results even more precise.
    8. Text Search
╳
Add to...
You have not created any category. Kindly create one to bookmark this item!
✕
Create New Category
Hide
Title :
Description :
❮❮ Hide
❮ Default View
Expand ❯❯
Close ✕
🔎 Highlights - Adv. Search ❯
TEXT SEARCH:

Press 'Enter' to add multiple search terms. Rules for Better Search

Search In:
Main Text + AI Text ❯
  • Main Text
  • Main Text + AI Text
  • AI Text
Law:
---- All Laws---- ❯
  • ---- All Laws----
  • Income Tax
  • Direct Taxes
  • Benami Property
  • Central GST Laws
  • SGST - State GST Laws
  • Customs
  • FTP - Foreign Trade Policy
  • SEZ - Special Economic Zone
  • FEMA - Foreign Exchange Management
  • Companies Law
  • SEBI - Securities & Exchange Board of India
  • IBC - Insolvency and Bankruptcy
  • Law of Competition
  • PMLA - Money-Laundering
  • Indian Laws
  • Bill / Finance Bills
  • Wealth Tax
  • Service Tax
  • Central Excise
  • VAT / Sales Tax
Month:
---- All Months ---- ❯
  • ---- All Months ----
  • January
  • February
  • March
  • April
  • May
  • June
  • July
  • August
  • September
  • October
  • November
  • December
Year:
---- All Years ---- ❯
  • ---- All Years ----
  • 2026
  • 2025
  • 2024
  • 2023
  • 2022
  • 2021
  • 2020
  • 2019
  • 2018
  • 2017
  • 2016
  • 2015
  • 2014
  • 2013
  • 2012
  • 2011
Sort By: ?
In Sort By 'Default', exact matches for text search are shown at the top, followed by the remaining results in their regular order.
Relevance Default Date
    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...
    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
    June 9, 2026   Case Laws Customs
    Customs valuation enhancement fails when based on a retracted statement and non-comparable contemporaneous import invoices.
    June 9, 2026   Case Laws Service Tax
    Transportation charges and foreign-branch services were held outside service tax, while disclosed records defeated extended limitation.
    June 9, 2026   Case Laws Service Tax
    Negative list treatment for food grain transport without consignment notes defeats service tax and extended limitation demand.
❮
❯
❯❯
Maximize Maximize Maximize
0 / 200
Expand Note
Add to Folder

No Folders have been created

+

Are you sure you want to delete "My most important" ?

NOTE:

Open Link
Highlights
Showing Results for :
Reset Filters
Results Found:
Show All Summaries Hide All Summaries
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
June 9, 2026   Case Laws Customs
Customs valuation enhancement fails when based on a retracted statement and non-comparable contemporaneous import invoices.
June 9, 2026   Case Laws Service Tax
Transportation charges and foreign-branch services were held outside service tax, while disclosed records defeated extended limitation.
June 9, 2026   Case Laws Service Tax
Negative list treatment for food grain transport without consignment notes defeats service tax and extended limitation demand.

Highlights

Back

All Highlights

Showing Results for :
Reset Filters
No Records Found

Highlights

Home › Highlights › Income Tax › 2012 › August, 2012 › This
Back

All Highlights

whatsapp Join Channel
Showing Results for : Reset Filters
Income Tax

Mischief of 'royalty' u/s 9(1) - payment made for transfer of...

Software Usage Payments Classified as 'Royalty' Under Income Tax Act Section 9(1), Subject to Royalty Taxation.

Contents
Summary
Note

Note

-

Bookmark

Print

Print

Print Options

Income Tax August 4, 2012 Case Laws HC
Mischief of 'royalty' u/s 9(1) - payment made for transfer of the right to use the software/computer programme in respect of the copyrights falls within the mischief of 'royalty' - HC
View Source View

Topics

Acts Income Tax
Next ➔