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    June 23, 2026   Case LawsFEMA
    FERA show-cause notices after repeal were quashed for lack of jurisdiction under the FEMA savings scheme
    June 23, 2026   Case LawsGST
    Composite show cause notices covering multiple assessment years are unsustainable; separate notices and limitation exclusion follow.
    June 23, 2026   Case LawsIncome Tax
    Advertising contract classification for Google AdWords payments prevailed over technical services treatment, so Section 194C TDS applied.
    June 23, 2026   Case LawsIncome Tax
    Cost-to-cost reimbursements and LIBOR-based receivables interest were accepted, with withholding and transfer pricing additions deleted.
    June 23, 2026   Case LawsIncome Tax
    Discounted cash flow share premium valuation and no-exempt-income rule: additions deleted, with prospective amendment held inapplicable
    June 23, 2026   Case LawsIncome Tax
    Territorial jurisdiction of Assessing Officer: notice by a non-jurisdictional officer held invalid, assessments quashed.
    June 23, 2026   Case LawsIncome Tax
    Adequate enquiry bars revision under section 263 where trust advance to a specified person was examined
    June 23, 2026   Case LawsIncome Tax
    Cross-examination and corroboration defeat penalty for alleged cash loan based only on third-party statements and loose papers.
    June 23, 2026   Case LawsIncome Tax
    Under-reporting penalty and 14A disallowance deleted where the notice was wrongly framed and no exempt income existed
    June 23, 2026   Case LawsIncome Tax
    Fair market value under section 50C must reflect existing property condition, not hypothetical development, and statutory valuation steps must be foll...
    June 23, 2026   Case LawsIncome Tax
    Search assessment additions require incriminating material; estimated stock and third-party ledger claims failed, while limited profit addition surviv...
    June 23, 2026   Case LawsIncome Tax
    Bank tax deductions and depreciation claims upheld as unrealised forex gains and MAT challenges failed entirely
    June 23, 2026   Case LawsIncome Tax
    Section 10AA deduction and reassessment scope: partner remuneration omission and unrelated additions were both held unsustainable
    June 23, 2026   Case LawsIncome Tax
    Protective addition and commission income fail where cash and profit were owned up by others; seized gold requires verification
    June 23, 2026   Case LawsIncome Tax
    ESOP discount deduction and no-exempt-income rule under section 14A supported deletion of tax disallowances.
    June 23, 2026   Case LawsIncome Tax
    Reopening after scrutiny assessment fails where recorded reasons rest on a false premise and show non-application of mind
    June 23, 2026   Case LawsIncome Tax
    Uncorroborated search material cannot sustain protective additions when seized papers lack corroboration and no fresh evidence emerges.
    June 23, 2026   Case LawsIncome Tax
    Section 153C jurisdiction turns on receipt of seized material date, not searched person's search date, for other person assessments.
    June 23, 2026   Case LawsIncome Tax
    DSIR-approved R&D deduction and APA-aligned transfer pricing adjustments were limited, while double disallowance was rejected.
    June 23, 2026   Case LawsIncome Tax
    Condonation of initial non-compliance with assessment notices bars penalty where later replies are accepted in assessment.
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    June 23, 2026   Case Laws FEMA
    FERA show-cause notices after repeal were quashed for lack of jurisdiction under the FEMA savings scheme
    June 23, 2026   Case Laws GST
    Composite show cause notices covering multiple assessment years are unsustainable; separate notices and limitation exclusion follow.
    June 23, 2026   Case Laws Income Tax
    Advertising contract classification for Google AdWords payments prevailed over technical services treatment, so Section 194C TDS applied.
    June 23, 2026   Case Laws Income Tax
    Cost-to-cost reimbursements and LIBOR-based receivables interest were accepted, with withholding and transfer pricing additions deleted.
    June 23, 2026   Case Laws Income Tax
    Discounted cash flow share premium valuation and no-exempt-income rule: additions deleted, with prospective amendment held inapplicable
    June 23, 2026   Case Laws Income Tax
    Territorial jurisdiction of Assessing Officer: notice by a non-jurisdictional officer held invalid, assessments quashed.
    June 23, 2026   Case Laws Income Tax
    Adequate enquiry bars revision under section 263 where trust advance to a specified person was examined
    June 23, 2026   Case Laws Income Tax
    Cross-examination and corroboration defeat penalty for alleged cash loan based only on third-party statements and loose papers.
    June 23, 2026   Case Laws Income Tax
    Under-reporting penalty and 14A disallowance deleted where the notice was wrongly framed and no exempt income existed
    June 23, 2026   Case Laws Income Tax
    Fair market value under section 50C must reflect existing property condition, not hypothetical development, and statutory valuation steps must be followed.
    June 23, 2026   Case Laws Income Tax
    Search assessment additions require incriminating material; estimated stock and third-party ledger claims failed, while limited profit addition survived.
    June 23, 2026   Case Laws Income Tax
    Bank tax deductions and depreciation claims upheld as unrealised forex gains and MAT challenges failed entirely
    June 23, 2026   Case Laws Income Tax
    Section 10AA deduction and reassessment scope: partner remuneration omission and unrelated additions were both held unsustainable
    June 23, 2026   Case Laws Income Tax
    Protective addition and commission income fail where cash and profit were owned up by others; seized gold requires verification
    June 23, 2026   Case Laws Income Tax
    ESOP discount deduction and no-exempt-income rule under section 14A supported deletion of tax disallowances.
    June 23, 2026   Case Laws Income Tax
    Reopening after scrutiny assessment fails where recorded reasons rest on a false premise and show non-application of mind
    June 23, 2026   Case Laws Income Tax
    Uncorroborated search material cannot sustain protective additions when seized papers lack corroboration and no fresh evidence emerges.
    June 23, 2026   Case Laws Income Tax
    Section 153C jurisdiction turns on receipt of seized material date, not searched person's search date, for other person assessments.
    June 23, 2026   Case Laws Income Tax
    DSIR-approved R&D deduction and APA-aligned transfer pricing adjustments were limited, while double disallowance was rejected.
    June 23, 2026   Case Laws Income Tax
    Condonation of initial non-compliance with assessment notices bars penalty where later replies are accepted in assessment.

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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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