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October 6, 2026   Case Laws GST
Electronic Cash Ledger balances do not discharge GST return liabilities until debit, sustaining interest on delayed return filing.
October 6, 2026   Case Laws Income Tax
Duplicate PAN cancellation timeframe requires prior administrative representation before judicial intervention, ensuring a time-bound decision on the request.
October 6, 2026   Case Laws Income Tax
Upper turnover filters in software transfer pricing comparability were upheld, defeating the Revenue's challenge to selected comparable companies.
October 6, 2026   Case Laws Income Tax
GST refund taxability: Audit-report disclosure alone does not convert unclaimed indirect-tax refunds into taxable income.
October 6, 2026   Case Laws Income Tax
Omission without a saving clause removes the basis for penalties tied to Form 3CEB reporting of specified domestic transactions.
October 6, 2026   Case Laws Income Tax
Conditional stay of transfer-pricing demand requires deposit and cooperation pending early disposal of the appeal process.
October 6, 2026   Case Laws Income Tax
Mandatory draft assessment orders protect non-resident eligible assessees from jurisdictionally defective reassessments involving prejudicial variations.
October 6, 2026   Case Laws Customs
Extended limitation for wrongly exempted special additional duty sustained, while related interest and penalty were set aside.
October 6, 2026   Case Laws SEBI
Cross-segment derivatives manipulation triggered market-access restraints and preservation of alleged wrongful gains through interim directions pending investigation.
October 6, 2026   Case Laws IBC
Natural justice and pre-CIRP labour awards protect termination compensation, permitting withdrawal of court deposits despite later insolvency resolution plans.
October 6, 2026   Case Laws Money Laundering
Look Out Circulars require demonstrated flight risk or investigation obstruction and cannot persist solely during pending inquiries.
October 6, 2026   Case Laws Money Laundering
Nexus between cash and proceeds of crime established through excise-evasion evidence and uncorroborated source claims.
October 6, 2026   Case Laws Central Excise
Known encumbrances in SARFAESI auctions remain payable before property can be delivered free of departmental attachments.
October 6, 2026   Case Laws Indian Laws
Arbitration of SEZ sub-lease monetary claims preserves rent, maintenance, termination, improvements and damages disputes while unused premises are vacated.
October 5, 2026   Notifications Income Tax
Scientific research approval grants a research association tax recognition, subject to annual donor reporting, certification, and regulatory compliance.
October 5, 2026   Circulars Customs
Import permits for non-insecticidal pesticide use now require Form IA applications, verified supporting records, and compliance with revised rules.
October 5, 2026   Circulars DGFT
Trade finance governance: revised Sub-Committee structure applies uniformly across Niryat Protsahan interventions under the Export Promotion Mission.
October 5, 2026   Circulars FEMA
Non-resident deposit reporting shifts to CIMS Sankalan, requiring monthly NRD-CSR submissions through approved digital reporting channels.
October 5, 2026   Circulars FEMA
Board-approved internal guidelines for Form A2 outward remittances may now be approved by delegated Board or management committees.
October 5, 2026   Notes Income Tax
Reassessment limitation excludes reply time but preserves a finite statutory period for completing the pre-notice process.

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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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