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    October 27, 2026   Case Laws Income Tax
    Jurisdictional sanction requirements bar reassessment when approval comes from an authority lacking statutory competence under the applicable framewor...
    October 27, 2026   Case Laws Income Tax
    Time-bound disposal of first income-tax appeals treats prolonged pendency as genuine hardship and requires expeditious adjudication.
    October 27, 2026   Case Laws Income Tax
    Recorded sales receipts cannot be reassessed as unexplained cash credits, eliminating the basis for consequential alleged commission expenditure addit...
    October 27, 2026   Case Laws Income Tax
    Assessment revision cannot rest solely on unrecorded reasons where the Assessing Officer examined and accepted explanations on disputed claims.
    October 27, 2026   Case Laws Income Tax
    Rectification jurisdiction limits bar merits review, requiring a fresh lawful consideration of the rejected application.
    October 27, 2026   Case Laws Income Tax
    Charitable registration for real-estate development societies turns on objects viewed as a whole, not isolated member-welfare clauses.
    October 27, 2026   Case Laws Income Tax
    Search-derived material requires search-assessment proceedings, rendering reassessment notices based solely on that material jurisdictionally invalid.
    October 27, 2026   Case Laws Income Tax
    Sufficient cause for delayed income-tax appeals requires bona fide diligence; unsubstantiated counsel illness and assessee inaction defeat condonation...
    October 27, 2026   Case Laws Income Tax
    Foundational assessment orders: setting them aside for fresh assessment defeats dependent tax-evasion prosecution and resulting convictions.
    October 27, 2026   Case Laws Income Tax
    Reasonable cause for cash property-sale advances can preclude penalty despite prescribed-mode receipt requirements and technical contravention.
    October 27, 2026   Case Laws Income Tax
    TNMM Segmentation Limits Transfer-Pricing Adjustments to Associated-Enterprise Transactions and Requires Turnover-Based Comparable Selection for IT Se...
    October 27, 2026   Case Laws Income Tax
    Related-party transaction filters and functional differences require exclusion of unreliable TNMM comparables in contact-centre service benchmarking.
    October 27, 2026   Case Laws Income Tax
    Transfer-pricing documentation penalty cannot survive where the underlying adjustment is deleted, and the Revenue challenge fails on consistent facts.
    October 27, 2026   Case Laws Income Tax
    Compulsorily convertible debentures remain debt before conversion, barring nil transfer-pricing interest adjustments and related disallowance.
    October 27, 2026   Case Laws Income Tax
    Internal TNMM supports deletion of freight-forwarding adjustments where comparable non-AE transactions are separately identifiable and materially simi...
    October 27, 2026   Case Laws Income Tax
    Cloud Application and IT Support Receipts Fail Royalty and Technical Service Tests Under the India-Netherlands Treaty
    October 27, 2026   Case Laws Income Tax
    Rectification appeal limitation runs from refusal order, while contingent-liability disclosures cannot justify disallowing unclaimed deductions.
    October 27, 2026   Case Laws Income Tax
    Arm's-length range treatment protects royalty payments within range, while evidence-based intra-group services cannot receive a nil valuation.
    October 27, 2026   Case Laws Income Tax
    Composite residential houses can qualify for Section 54F despite separate flat registrations, subject to proof of functional interconnection.
    October 27, 2026   Case Laws Income Tax
    Section 43CB excludes self-developed projects undertaken and sold at the developer's own commercial risk, preserving project-completion accounting.
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October 27, 2026   Case Laws Income Tax
Jurisdictional sanction requirements bar reassessment when approval comes from an authority lacking statutory competence under the applicable framework.
October 27, 2026   Case Laws Income Tax
Time-bound disposal of first income-tax appeals treats prolonged pendency as genuine hardship and requires expeditious adjudication.
October 27, 2026   Case Laws Income Tax
Recorded sales receipts cannot be reassessed as unexplained cash credits, eliminating the basis for consequential alleged commission expenditure additions.
October 27, 2026   Case Laws Income Tax
Assessment revision cannot rest solely on unrecorded reasons where the Assessing Officer examined and accepted explanations on disputed claims.
October 27, 2026   Case Laws Income Tax
Rectification jurisdiction limits bar merits review, requiring a fresh lawful consideration of the rejected application.
October 27, 2026   Case Laws Income Tax
Charitable registration for real-estate development societies turns on objects viewed as a whole, not isolated member-welfare clauses.
October 27, 2026   Case Laws Income Tax
Search-derived material requires search-assessment proceedings, rendering reassessment notices based solely on that material jurisdictionally invalid.
October 27, 2026   Case Laws Income Tax
Sufficient cause for delayed income-tax appeals requires bona fide diligence; unsubstantiated counsel illness and assessee inaction defeat condonation.
October 27, 2026   Case Laws Income Tax
Foundational assessment orders: setting them aside for fresh assessment defeats dependent tax-evasion prosecution and resulting convictions.
October 27, 2026   Case Laws Income Tax
Reasonable cause for cash property-sale advances can preclude penalty despite prescribed-mode receipt requirements and technical contravention.
October 27, 2026   Case Laws Income Tax
TNMM Segmentation Limits Transfer-Pricing Adjustments to Associated-Enterprise Transactions and Requires Turnover-Based Comparable Selection for IT Services
October 27, 2026   Case Laws Income Tax
Related-party transaction filters and functional differences require exclusion of unreliable TNMM comparables in contact-centre service benchmarking.
October 27, 2026   Case Laws Income Tax
Transfer-pricing documentation penalty cannot survive where the underlying adjustment is deleted, and the Revenue challenge fails on consistent facts.
October 27, 2026   Case Laws Income Tax
Compulsorily convertible debentures remain debt before conversion, barring nil transfer-pricing interest adjustments and related disallowance.
October 27, 2026   Case Laws Income Tax
Internal TNMM supports deletion of freight-forwarding adjustments where comparable non-AE transactions are separately identifiable and materially similar.
October 27, 2026   Case Laws Income Tax
Cloud Application and IT Support Receipts Fail Royalty and Technical Service Tests Under the India-Netherlands Treaty
October 27, 2026   Case Laws Income Tax
Rectification appeal limitation runs from refusal order, while contingent-liability disclosures cannot justify disallowing unclaimed deductions.
October 27, 2026   Case Laws Income Tax
Arm's-length range treatment protects royalty payments within range, while evidence-based intra-group services cannot receive a nil valuation.
October 27, 2026   Case Laws Income Tax
Composite residential houses can qualify for Section 54F despite separate flat registrations, subject to proof of functional interconnection.
October 27, 2026   Case Laws Income Tax
Section 43CB excludes self-developed projects undertaken and sold at the developer's own commercial risk, preserving project-completion accounting.

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Income Tax

Benefits of India UAE Double Taxation Avoidance Agreement - the...

UAE Company Entitled to India-UAE Tax Treaty Benefits; Article 29 Limitations Do Not Apply Per Article 4(1)(b).

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Income Tax May 5, 2021 Case Laws AT
Benefits of India UAE Double Taxation Avoidance Agreement - the assessee company is a resident of the UAE, in terms of requirements of article 4(1)(b) of the Indo-UAE tax treaty, that the limitation of benefits provisions of article 29 of the Indo-UAE tax treaty cannot be pressed into service in this case, and that the assessee is eligible for treaty protection, in respect of its income earned in India, under the Indo UAE tax treaty. - AT
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