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    July 16, 2026   Case LawsGST
    Duplicative GST adjudication for the same issues and assessment period invalidates subsequent State GST assessment and rectification orders.
    July 16, 2026   Case LawsGST
    Statutory GST liability overrides works-contract reimbursement disputes, limiting contractual claims and barring non-statutory return or waiver relief...
    July 16, 2026   Case LawsGST
    E-way bill compliance applies to machinery returned for testing under delivery challans, despite no taxable supply arising.
    July 16, 2026   Case LawsGST
    Excess input tax credit beyond reflected supplier data attracts extended-period assessment, interest and penalty; turnover mismatch requires documenta...
    July 16, 2026   Case LawsGST
    Arrest authorisation under GST law is required before anticipatory bail can be considered, with limited interim protection available.
    July 16, 2026   Case LawsGST
    Condonation beyond the statutory appeal-delay cap under GST awaits consideration after analogous appeals are placed before the Tribunal.
    July 16, 2026   Case LawsIncome Tax
    Effective hearing in faceless reassessment requires notices to reach the assessee, prompting remand for fresh assessment proceedings.
    July 16, 2026   Case LawsIncome Tax
    Wilful tax-payment evasion requires evidence beyond delayed payment; financial constraints and later payment negate prosecution.
    July 16, 2026   Case LawsIncome Tax
    Minimum alternate tax exclusions for pre-amendment banking companies and expatriate Indian branch salaries remain outside head office expenditure limi...
    July 16, 2026   Case LawsIncome Tax
    Closing stock bank statements alone cannot justify tax additions where books are sound and valuation differences are reconciled.
    July 16, 2026   Case LawsIncome Tax
    Penalty recovery stay: delayed TDS deduction and remittance may not attract Section 271C, pending appellate determination.
    July 16, 2026   Case LawsIncome Tax
    Interest on delayed statutory payments is deductible only where the underlying liability qualifies as business expenditure.
    July 16, 2026   Case LawsIncome Tax
    Futures and options turnover computation kept derivatives activity below the tax-audit threshold, resulting in deletion of non-furnishing penalty.
    July 16, 2026   Case LawsIncome Tax
    Share premium valuation requires examination of supporting reports, while limited scrutiny restricts additions beyond the selected issues.
    July 16, 2026   Case LawsIncome Tax
    Revision limitation for issues outside reassessment runs from the original assessment, rendering delayed revision proceedings time-barred.
    July 16, 2026   Case LawsIncome Tax
    Per-payment TDS threshold limits online gaming withholding, while unclaimed player payouts cannot trigger expenditure disallowance under tax law.
    July 16, 2026   Case LawsIncome Tax
    Section 87A rebate remains available against short-term capital gains where the relevant law contained no express exclusion.
    July 16, 2026   Case LawsIncome Tax
    Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
    July 16, 2026   Case LawsIncome Tax
    Estimated business expenditure for unsupported commission expenses increased after considering the nature and circumstances of commission activities.
    July 16, 2026   Case LawsIncome Tax
    Intra-group software licence costs require evidence of actual use, while comparable selection must reflect functional and scale differences.
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    July 16, 2026   Case Laws GST
    Duplicative GST adjudication for the same issues and assessment period invalidates subsequent State GST assessment and rectification orders.
    July 16, 2026   Case Laws GST
    Statutory GST liability overrides works-contract reimbursement disputes, limiting contractual claims and barring non-statutory return or waiver relief.
    July 16, 2026   Case Laws GST
    E-way bill compliance applies to machinery returned for testing under delivery challans, despite no taxable supply arising.
    July 16, 2026   Case Laws GST
    Excess input tax credit beyond reflected supplier data attracts extended-period assessment, interest and penalty; turnover mismatch requires documentary support.
    July 16, 2026   Case Laws GST
    Arrest authorisation under GST law is required before anticipatory bail can be considered, with limited interim protection available.
    July 16, 2026   Case Laws GST
    Condonation beyond the statutory appeal-delay cap under GST awaits consideration after analogous appeals are placed before the Tribunal.
    July 16, 2026   Case Laws Income Tax
    Effective hearing in faceless reassessment requires notices to reach the assessee, prompting remand for fresh assessment proceedings.
    July 16, 2026   Case Laws Income Tax
    Wilful tax-payment evasion requires evidence beyond delayed payment; financial constraints and later payment negate prosecution.
    July 16, 2026   Case Laws Income Tax
    Minimum alternate tax exclusions for pre-amendment banking companies and expatriate Indian branch salaries remain outside head office expenditure limits.
    July 16, 2026   Case Laws Income Tax
    Closing stock bank statements alone cannot justify tax additions where books are sound and valuation differences are reconciled.
    July 16, 2026   Case Laws Income Tax
    Penalty recovery stay: delayed TDS deduction and remittance may not attract Section 271C, pending appellate determination.
    July 16, 2026   Case Laws Income Tax
    Interest on delayed statutory payments is deductible only where the underlying liability qualifies as business expenditure.
    July 16, 2026   Case Laws Income Tax
    Futures and options turnover computation kept derivatives activity below the tax-audit threshold, resulting in deletion of non-furnishing penalty.
    July 16, 2026   Case Laws Income Tax
    Share premium valuation requires examination of supporting reports, while limited scrutiny restricts additions beyond the selected issues.
    July 16, 2026   Case Laws Income Tax
    Revision limitation for issues outside reassessment runs from the original assessment, rendering delayed revision proceedings time-barred.
    July 16, 2026   Case Laws Income Tax
    Per-payment TDS threshold limits online gaming withholding, while unclaimed player payouts cannot trigger expenditure disallowance under tax law.
    July 16, 2026   Case Laws Income Tax
    Section 87A rebate remains available against short-term capital gains where the relevant law contained no express exclusion.
    July 16, 2026   Case Laws Income Tax
    Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protection.
    July 16, 2026   Case Laws Income Tax
    Estimated business expenditure for unsupported commission expenses increased after considering the nature and circumstances of commission activities.
    July 16, 2026   Case Laws Income Tax
    Intra-group software licence costs require evidence of actual use, while comparable selection must reflect functional and scale differences.

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      Home› Highlights › Income Tax › 2021 › July, 2021 › This
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      Income Tax

      TP Adjustment - 'arranged' pricing' - TNMM method or CUP method...

      Court Rules CUP Method More Suitable Than TNMM for Determining Arm's Length Price in Transfer Pricing Case.

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      Income TaxJuly 19, 2021Case LawsHC
      TP Adjustment - 'arranged' pricing' - TNMM method or CUP method - the superiority of any particular method to arrive at the ALP is ruled out.The TNMM (Transactional Net Margin Method) requires establishing comparability level at a broad functional level. It requires comparison between net margin derived from operation of the uncontrolled parties and net margin derived by an associated enterprise on similar operation. The net profit margin earned by an associate enterprise is compared with net profit margin of uncontrolled transactions to arrive at arm's length price. - Thus CUP method was found to be more appropriate - HC
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