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    June 9, 2026   Case LawsGST
    GST refund deficiency memos must specify exact defects; vague RFD-03 notices cannot sustain rejection of refund claims
    June 9, 2026   Case LawsGST
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    June 9, 2026   Case LawsIncome Tax
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    June 9, 2026   Case LawsIncome Tax
    Retrospective reassessment amendment kept notice challenges open on remand, with liberty to contest the new provision.
    June 9, 2026   Case LawsIncome Tax
    Decretal interest as judgment debt cannot be subjected to TDS deduction by the judgment debtor absent decree authorisation.
    June 9, 2026   Case LawsIncome Tax
    Compensatory interest for wrongful retention of seized KVPs and IVPs allowed until release, with simple interest on arrears.
    June 9, 2026   Case LawsIncome Tax
    Co-operative bank TDS exemption turned on binding CBDT note, while the restrictive proviso survived constitutional challenge.
    June 9, 2026   Case LawsIncome Tax
    Black Money Act limitation and TOLA extensions: assessment quashed as time-barred because the notifications did not apply.
    June 9, 2026   Case LawsIncome Tax
    Royalty and FIS/FTS treatment of database recharge and seconded employee reimbursements under India-USA DTAA held non-taxable
    June 9, 2026   Case LawsIncome Tax
    Article 8 shipping receipts from feeder vessels and slot hire held covered by the DTAA, not separately taxed.
    June 9, 2026   Case LawsIncome Tax
    Arrears of superannuation fund perquisites qualify for salary relief, and Rule 21A applies to the claim.
    June 9, 2026   Case LawsIncome Tax
    Burden of proof in penalty cases defeats cash-loan penalties based only on third-party seized papers
    June 9, 2026   Case LawsIncome Tax
    Royalty and management support service adjustments fail where costs were recovered and aggregated TNMM benchmarking applied.
    June 9, 2026   Case LawsIncome Tax
    Transfer pricing adjustments remanded for fresh review of intra-group services, sensor assembling method and comparables analysis
    June 9, 2026   Case LawsIncome Tax
    Foreign asset disclosure in a substituted return can defeat penalty for an earlier omission when assessment accepts it.
    June 9, 2026   Case LawsIncome Tax
    Comparability filters in TNMM require upfront R&D screening and broadly similar turnover scales for software services.
    June 9, 2026   Case LawsIncome Tax
    Functional comparability in wholesale auto-component trading excludes retail and after-sales comparables, deleting transfer pricing adjustments
    June 9, 2026   Case LawsIncome Tax
    Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
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    June 9, 2026   Case Laws GST
    GST refund deficiency memos must specify exact defects; vague RFD-03 notices cannot sustain rejection of refund claims
    June 9, 2026   Case Laws GST
    Alternate remedy and natural justice limits kept the writ challenge to a CGST adjudication order out of writ jurisdiction
    June 9, 2026   Case Laws GST
    Writ jurisdiction and alternative remedy in GST disputes: factual issues and no natural justice breach sent parties to appeal
    June 9, 2026   Case Laws Income Tax
    Mandatory pre-cognizance hearing under BNSS applies when cognizance is taken after commencement, vitiating orders without notice.
    June 9, 2026   Case Laws Income Tax
    Site restoration deduction upheld; reassessment quashed for lack of reasons and notice beyond limitation
    June 9, 2026   Case Laws Income Tax
    Retrospective reassessment amendment kept notice challenges open on remand, with liberty to contest the new provision.
    June 9, 2026   Case Laws Income Tax
    Decretal interest as judgment debt cannot be subjected to TDS deduction by the judgment debtor absent decree authorisation.
    June 9, 2026   Case Laws Income Tax
    Compensatory interest for wrongful retention of seized KVPs and IVPs allowed until release, with simple interest on arrears.
    June 9, 2026   Case Laws Income Tax
    Co-operative bank TDS exemption turned on binding CBDT note, while the restrictive proviso survived constitutional challenge.
    June 9, 2026   Case Laws Income Tax
    Black Money Act limitation and TOLA extensions: assessment quashed as time-barred because the notifications did not apply.
    June 9, 2026   Case Laws Income Tax
    Royalty and FIS/FTS treatment of database recharge and seconded employee reimbursements under India-USA DTAA held non-taxable
    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.

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

      TDS u/s 195 - Royalty - Assessee purchased certain software...

      Software License Payments Deemed Taxable Royalties Under DTAA and Section 9(1)(vi) of Income Tax Act.

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      Income TaxDecember 29, 2019Case LawsAT
      TDS u/s 195 - Royalty - Assessee purchased certain software licenses from M/s.Saipem SPA, Italy, which were used by assessee for providing services to customers for various support functions in accounting, reporting, etc.- payments towards grant of license/software are taxable as Royalty both under DTAA as well under provisions of Section 9(1)(vi)
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