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    July 23, 2026   Circulars SEZ
    RFID sealing for SEZ export containers becomes the sole required mechanism, preventing additional sealing demands at gateway ports.
    July 23, 2026   Case Laws GST
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    July 23, 2026   Case Laws GST
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    July 23, 2026   Case Laws GST
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    July 23, 2026   Case Laws GST
    De novo GST adjudication granted subject to conditional pre-deposit, substantiated reply, and compliance with fresh-hearing requirements.
    July 23, 2026   Case Laws Income Tax
    Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
    July 23, 2026   Case Laws Income Tax
    Statutory bar on probation invalidates release of a person convicted for making a false income-tax return statement.
    July 23, 2026   Case Laws Income Tax
    Ten-year reassessment limitation includes the search assessment year in search cases, rendering notices beyond the period time-barred.
    July 23, 2026   Case Laws Income Tax
    Reasonable cause for inadvertent Form 3CD omissions can prevent penalty where software error and no mala fide intent are shown.
    July 23, 2026   Case Laws Income Tax
    Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
    July 23, 2026   Case Laws Income Tax
    Redeveloped flat holding period follows original ownership rights, supporting long-term capital gains, indexed cost and residential-house exemption.
    July 23, 2026   Case Laws Income Tax
    Dependent agent permanent establishment attribution was deleted, while unexamined refund interest required fresh consideration after adequate hearing.
    July 23, 2026   Case Laws Income Tax
    Profit embedded in unaccounted business receipts was taxed at a 1% gross-profit rate; unsupported salary and asset additions failed.
    July 23, 2026   Case Laws Income Tax
    Effective opportunity to explain foreign bank credits required remand for fresh appellate consideration with supporting evidence.
    July 23, 2026   Case Laws Income Tax
    Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
    July 23, 2026   Case Laws Income Tax
    Related-party interest deductions require excess over fair market value, while unsupported software and brokerage claims remain disallowable.
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July 23, 2026   Circulars SEZ
RFID sealing for SEZ export containers becomes the sole required mechanism, preventing additional sealing demands at gateway ports.
July 23, 2026   Case Laws GST
Assignment of leasehold rights treated as transfer arising from land, with GST held not leviable on the transaction.
July 23, 2026   Case Laws GST
Interest on delayed GST payments cannot be charged after timely Electronic Cash Ledger credit; excess interest refund follows.
July 23, 2026   Case Laws GST
Instalment payment of outstanding GST interest continues until December 2026, subject to automatic withdrawal upon any payment default.
July 23, 2026   Case Laws GST
E-way bill expiry alone cannot justify goods detention when breakdown delays delivery without evidence of tax evasion.
July 23, 2026   Case Laws GST
Financial incapacity may support a waiver request for mandatory pre-deposit before the appellate authority in exceptional circumstances.
July 23, 2026   Case Laws GST
Natural justice requires a further opportunity to substantiate disputed input tax credit transactions before final demand determination.
July 23, 2026   Case Laws GST
Properly addressed show cause notice is essential for GST adjudication; orders based on notice to another entity were quashed.
July 23, 2026   Case Laws GST
De novo GST adjudication granted subject to conditional pre-deposit, substantiated reply, and compliance with fresh-hearing requirements.
July 23, 2026   Case Laws Income Tax
Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a clean slate.
July 23, 2026   Case Laws Income Tax
Statutory bar on probation invalidates release of a person convicted for making a false income-tax return statement.
July 23, 2026   Case Laws Income Tax
Ten-year reassessment limitation includes the search assessment year in search cases, rendering notices beyond the period time-barred.
July 23, 2026   Case Laws Income Tax
Reasonable cause for inadvertent Form 3CD omissions can prevent penalty where software error and no mala fide intent are shown.
July 23, 2026   Case Laws Income Tax
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years.
July 23, 2026   Case Laws Income Tax
Redeveloped flat holding period follows original ownership rights, supporting long-term capital gains, indexed cost and residential-house exemption.
July 23, 2026   Case Laws Income Tax
Dependent agent permanent establishment attribution was deleted, while unexamined refund interest required fresh consideration after adequate hearing.
July 23, 2026   Case Laws Income Tax
Profit embedded in unaccounted business receipts was taxed at a 1% gross-profit rate; unsupported salary and asset additions failed.
July 23, 2026   Case Laws Income Tax
Effective opportunity to explain foreign bank credits required remand for fresh appellate consideration with supporting evidence.
July 23, 2026   Case Laws Income Tax
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded.
July 23, 2026   Case Laws Income Tax
Related-party interest deductions require excess over fair market value, while unsupported software and brokerage claims remain disallowable.

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Income Tax

PE in India - activities of Research and development activities...

R&D Activities Do Not Create Permanent Establishment in India; Taxable Only if Profits Accrue Locally - Article 7(1.

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Income Tax December 16, 2022 Case Laws HC
PE in India - activities of Research and development activities do not constitute a PE of the assessee in India - A plain reading of the Article 7(1) would show, that the issue of taxability would arise qua the respondent/assessee only if profits accrue to the respondent/assessee, and that too only to the extent they can be attributed to its PE in India. - HC
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Acts Income Tax
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