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    June 22, 2026   Case LawsIncome Tax
    Change of opinion bars reassessment where audit objections revisit depreciation, goodwill, CSR donations and discount provisions.
    June 22, 2026   Case LawsIncome Tax
    Intra-city case transfer without hearing validates transferee officer's jurisdiction and preserves assessment notices already issued
    June 22, 2026   Case LawsIncome Tax
    Minimum one-acre housing project rule bars clubbing separate residential land for deduction under section 80IB(10)
    June 22, 2026   Case LawsIncome Tax
    Residential house exemption and stamp duty tolerance band applied liberally despite COVID-related construction delay
    June 22, 2026   Case LawsIncome Tax
    Late loss return bars carry forward of short-term capital loss; subsequent-year set off denied under filing rule
    June 22, 2026   Case LawsIncome Tax
    Year-specific satisfaction note required for section 153C jurisdiction; common mechanical note vitiated assessment where seized material lacked nexus
    June 22, 2026   Case LawsIncome Tax
    Consistency in assessee's own case defeats notional interest addition on subsidiary loans; settled view was followed
    June 22, 2026   Case LawsIncome Tax
    Unexplained investment in property: banking trail and parent-funded payment defeated section 69 addition despite no gift deed.
    June 22, 2026   Case LawsIncome Tax
    Surrendered business income cannot be taxed as unexplained income absent an independent source; business treatment affirmed.
    June 22, 2026   Case LawsIncome Tax
    Under-reporting penalty for depreciation disallowance fails where a charitable trust's income remains nil and no tax is payable
    June 22, 2026   Case LawsIncome Tax
    Make available test under India-UK DTAA: managerial business support services were not fees for technical services
    June 22, 2026   Case LawsIncome Tax
    Convertible debentures remain debt until conversion, and pre-conversion interest plus receivable adjustments need fresh transfer pricing review.
    June 22, 2026   Case LawsIncome Tax
    Electronic receipt of DRP directions triggers limitation for final assessment, making a later order time-barred.
    June 22, 2026   Case LawsIncome Tax
    Revenue expenditure and business deduction claims upheld for IPL franchise, website, club and employee costs
    June 22, 2026   Case LawsIncome Tax
    Working capital adjustment, comparable selection and trade receivables interest were revisited in transfer pricing, with key additions deleted and rem...
    June 22, 2026   Case LawsIncome Tax
    Corporate guarantee commission and book profit computation require fact-based allocation and fresh recomputation after Section 14A exclusion
    June 22, 2026   Case LawsCustoms
    Customs classification disputes and show cause notices: writ interference declined, statutory adjudication required, natural justice plea left open.
    June 22, 2026   Case LawsCustoms
    Suspension of container freight station approval remanded after unargued contention, with interim revival of suspension order
    June 22, 2026   Case LawsCustoms
    Strict construction of baggage exclusion preserves tribunal jurisdiction over seized foreign currency disputes before customs clearance
    June 22, 2026   Case LawsIBC
    Writ jurisdiction over pending tribunal proceedings barred when alternative remedies exist; parallel filings treated as abuse of process
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    June 22, 2026   Case Laws Income Tax
    Change of opinion bars reassessment where audit objections revisit depreciation, goodwill, CSR donations and discount provisions.
    June 22, 2026   Case Laws Income Tax
    Intra-city case transfer without hearing validates transferee officer's jurisdiction and preserves assessment notices already issued
    June 22, 2026   Case Laws Income Tax
    Minimum one-acre housing project rule bars clubbing separate residential land for deduction under section 80IB(10)
    June 22, 2026   Case Laws Income Tax
    Residential house exemption and stamp duty tolerance band applied liberally despite COVID-related construction delay
    June 22, 2026   Case Laws Income Tax
    Late loss return bars carry forward of short-term capital loss; subsequent-year set off denied under filing rule
    June 22, 2026   Case Laws Income Tax
    Year-specific satisfaction note required for section 153C jurisdiction; common mechanical note vitiated assessment where seized material lacked nexus
    June 22, 2026   Case Laws Income Tax
    Consistency in assessee's own case defeats notional interest addition on subsidiary loans; settled view was followed
    June 22, 2026   Case Laws Income Tax
    Unexplained investment in property: banking trail and parent-funded payment defeated section 69 addition despite no gift deed.
    June 22, 2026   Case Laws Income Tax
    Surrendered business income cannot be taxed as unexplained income absent an independent source; business treatment affirmed.
    June 22, 2026   Case Laws Income Tax
    Under-reporting penalty for depreciation disallowance fails where a charitable trust's income remains nil and no tax is payable
    June 22, 2026   Case Laws Income Tax
    Make available test under India-UK DTAA: managerial business support services were not fees for technical services
    June 22, 2026   Case Laws Income Tax
    Convertible debentures remain debt until conversion, and pre-conversion interest plus receivable adjustments need fresh transfer pricing review.
    June 22, 2026   Case Laws Income Tax
    Electronic receipt of DRP directions triggers limitation for final assessment, making a later order time-barred.
    June 22, 2026   Case Laws Income Tax
    Revenue expenditure and business deduction claims upheld for IPL franchise, website, club and employee costs
    June 22, 2026   Case Laws Income Tax
    Working capital adjustment, comparable selection and trade receivables interest were revisited in transfer pricing, with key additions deleted and remitted.
    June 22, 2026   Case Laws Income Tax
    Corporate guarantee commission and book profit computation require fact-based allocation and fresh recomputation after Section 14A exclusion
    June 22, 2026   Case Laws Customs
    Customs classification disputes and show cause notices: writ interference declined, statutory adjudication required, natural justice plea left open.
    June 22, 2026   Case Laws Customs
    Suspension of container freight station approval remanded after unargued contention, with interim revival of suspension order
    June 22, 2026   Case Laws Customs
    Strict construction of baggage exclusion preserves tribunal jurisdiction over seized foreign currency disputes before customs clearance
    June 22, 2026   Case Laws IBC
    Writ jurisdiction over pending tribunal proceedings barred when alternative remedies exist; parallel filings treated as abuse of process

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      Home› Highlights › Income Tax › 2020 › July, 2020 › This
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      Income Tax

      Income accrued in India - Royalty receipt - management service...

      Indian Management Service Fees Not Classified as Royalty; No Technical Knowledge Transferred to SurfGold, Additions Deleted.

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      Income TaxJuly 28, 2020Case LawsAT
      Income accrued in India - Royalty receipt - management service fees - the management services are provided only to support SurfGold in carrying on its business efficiently and running the business in line with the business model, policies and best practices followed by the Edenred group. These services do not make available any technical knowledge, skill, knowhow or processes to SurfGold. - Additions deleted - AT
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