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    October 6, 2026   Case Laws Income Tax
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October 6, 2026   Case Laws Income Tax
Berry Ratio rejected for jewellery manufacturing; receivables interest depends on customer-credit parity and binding book-profit directions.
October 6, 2026   Case Laws Income Tax
Jurisdictional satisfaction for concealment penalty cannot be created later by substituting a distinct penal provision after assessment.
October 6, 2026   Case Laws Income Tax
Delayed trade receivables require independent arm's length benchmarking after the agreed credit period, using currency-appropriate interest rates.
October 6, 2026   Case Laws Income Tax
Compulsorily convertible debentures remain debt before conversion, preventing transfer-pricing and interest-deduction disallowances on the stated facts.
October 6, 2026   Case Laws Income Tax
Arm's length pricing of captive electricity follows the distribution licensee's supply rate, while penalty initiation challenges remain premature.
October 6, 2026   Case Laws Income Tax
Pass-through associated enterprise purchases require no arm's length adjustment where credit notes align prices with the unrelated supplier.
October 6, 2026   Case Laws Income Tax
Stock-in-trade transfer taxability follows possession and consideration, not later conveyance registration, limiting deemed-value provisions to the actual transfer year.
October 6, 2026   Case Laws Income Tax
Tax withholding on settlement compensation requires an identified statutory obligation before a disallowance can arise.
October 6, 2026   Case Laws Income Tax
Compulsorily convertible debentures remain debt until conversion, preventing transfer-pricing recharacterisation as equity without the GAAR procedure.
October 6, 2026   Case Laws Income Tax
Reciprocal plot exchanges: Consideration in kind prevents section 43CA valuation addition where no stamp-duty shortfall exists.
October 6, 2026   Case Laws Customs
Project-import contract registration before importation determines Heading 98.01 eligibility, while Section 18A permits qualifying post-clearance Bill revisions.
October 6, 2026   Case Laws IBC
Clean slate protection prevents enforcement of pre-CIRP export obligations through Denied Entry List restrictions after resolution approval.
October 6, 2026   Case Laws IBC
Resolution-plan feasibility fails where SEZ land conversion lacks consent and the Information Memorandum conceals regulatory uncertainty.
October 6, 2026   Case Laws GST
GST limitation turns on issuance of substantive notices and orders, not later electronic DRC summaries, preserving appellate review.
October 6, 2026   Case Laws GST
Rule 138B authorisation and alternative appellate remedies limited the writ challenge to confiscation proceedings involving scrap-goods transport.
October 6, 2026   Case Laws GST
Alternative statutory remedy under GST bars writ challenge where classification, notice variance, and hearing disputes require factual appellate review.
October 6, 2026   Case Laws GST
Writ jurisdiction over CGST penalties requires a clear natural-justice breach; record-dependent challenges belong in statutory appeal.
October 6, 2026   Case Laws GST
Anticipatory bail under GST requires a communicated arrest-authorisation order; summons alone make a pre-arrest petition premature.
October 6, 2026   Case Laws GST
Proof of statutory breach limits strict-liability transit penalties where consignee-address errors are bona fide and goods match documents.
October 6, 2026   Case Laws GST
Part B e-way bill exception protects initial intrastate movement to transporter premises from tax penalties.

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Home › Highlights › Income Tax › 2022 › December, 2022 › This
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Income Tax

TP Adjustment - rejecting the Internal Transactional Net Margin...

Court Approves All Comparables for External TNMM; No Transfer Pricing Adjustment Needed for Arm's Length Price.

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Income Tax December 9, 2022 Case Laws AT
TP Adjustment - rejecting the Internal Transactional Net Margin Method (TNMM) as Most Appropriate Method (MAM) - effectively all the 12 comparables chosen by the assessee, on without prejudice basis, for applying External TNMM gets approved. - there is no scope for making any adjustment to arm’s length price even if External TNMM is adopted in the instant case. - AT
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