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    November 11, 2025 Case Laws Income Tax
    Reassessment after four-year period invalid if based solely on change of opinion without concealment evidence under s.143(3)
    November 11, 2025 Case Laws Income Tax
    s.154 valid to correct record error and raise domestic company tax rate from 29% to 30% per Finance Act 2017
    November 11, 2025 Case Laws Income Tax
    Reassessment under section 147 held void ab initio where AO lacked cogent reasons; DTAA and section 194LD protections upheld
    November 11, 2025 Case Laws Income Tax
    Appeal upholds deletion of additions under s.68 and s.56(2)(x)(b)(B) after assessee proved loans with documentary evidence
    November 11, 2025 Case Laws Income Tax
    Appeal allowed; proviso to s.251(1)(a) exceeded-remand confined to s.36(1)(iii) disallowance; delete commercially expedient investments, verify linkag...
    November 11, 2025 Case Laws Income Tax
    Penalty under s.271D cancelled as s.269SS held inapplicable where advances received from non-owner and later refunded
    November 11, 2025 Case Laws Income Tax
    Payments to intermediary for collecting foreign college fees are not "royalty" under Income Tax Act, 1961; additions deleted
    November 11, 2025 Case Laws Customs
    Confiscation upheld for SEZ diversion; s.114A CA penalty limited to duty or interest; fresh adjudication under ss.112A/114 CA
    November 11, 2025 Case Laws IBC
    Appeal dismissed; KMP's fraudulent share transactions found to intend to defraud creditors, vitiating deals under Section 66(1)
    November 11, 2025 Case Laws Money Laundering
    PMLA provisional attachment order upheld; appeal dismissed as collateral quashing barred pending prosecution and trial-level evidence
    November 11, 2025 Case Laws Indian Laws
    Election rejected for failing to disclose s.138 conviction in Rule 24-A(1) affidavit; later acquittal not curative
    November 11, 2025 Case Laws GST
    s.73 KGST adjudication quashed for same period; ex parte orders set aside and matters remanded for fresh hearings
    November 11, 2025 Case Laws GST
    Initial appeal rejection for missing mandatory pre-deposit upheld; belated appeal time-barred; restore appeal if 25% cash deposit within 30 days
    November 11, 2025 Case Laws GST
    Ex parte order set aside after email notices landed in junk; matter remitted for fresh consideration under Section 73(9)
    November 11, 2025 Case Laws GST
    Partial relief: penalty of Rs.6,05,17,933 set aside for failure to apply Sections 74, 75 and improper use of Section 122
    November 11, 2025 Case Laws Indian Laws
    Rule 3 of Brick Kiln (Regulation) Rules, 2017 requires licences for manufacturers and dealers, including brick transporters; seizures upheld
    November 11, 2025 Case Laws Income Tax
    Appeal dismissed; factual findings upheld that alleged bank liabilities were rightly added due to insufficient evidence of transactions
    November 11, 2025 Case Laws Income Tax
    Appeal under s.249(4)(a) and s.158BC requires payment/deposit of admitted tax; no implied exception or waiver allowed
    November 11, 2025 Case Laws Income Tax
    Penalty under s.270A(9) deleted where disallowance stemmed from calculation error in s.54F deduction, not misrepresentation
    November 11, 2025 Case Laws Income Tax
    De novo transfer pricing verification ordered; LIBOR+200bps for trade receivables, 60-day credit; s.14A deleted, CSR disallowed under s.37(1)
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    Income Tax

    Characterizing subscription revenue received - Indian–United K...

    Indian-UK Tax Treaty: Subscription Revenue Classified as Royalty, Article 13(6) Inapplicable, Impact on Permanent Establishment in India.

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    Income TaxJanuary 5, 2020Case LawsAT

    Characterizing subscription revenue received - Indian–United Kingdom Tax Treaty - PE in India - not only the subscription fee is in the nature of royalty but the provision of Article–13(6) of the Tax Treaty would not be applicable to the assessee

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