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    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 protectio...
    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.
    July 16, 2026   Case Laws Customs
    Reasonable-time limits on duty drawback recovery bar unexplained delayed proceedings where fraud or suppression is not alleged.
    July 16, 2026   Case Laws Customs
    Specific LCD tariff classification prevails over end-use based controller classification, requiring fresh determination under Chapter 90.
    July 16, 2026   Case Laws Customs
    Provisional release for re-export remains available pending unresolved classification, despite alleged import restrictions on seized goods.
    July 16, 2026   Case Laws Customs
    Strict construction of customs exemptions denies ELISA-kit duty concession to separately imported QFT Tube components.
    July 16, 2026   Case Laws Customs
    Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
    July 16, 2026   Case Laws IBC
    Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
    July 16, 2026   Case Laws IBC
    Leasehold BOT rights can be liquidated as going-concern assets while preserving landowner rights and end-of-concession transfer obligations.
    July 16, 2026   Case Laws IBC
    Contractual development rights may be insolvency assets, but resolution plans cannot override third-party land title or statutory approvals.
    July 16, 2026   Case Laws Money Laundering
    Territorial jurisdiction under PMLA may be concurrent, allowing transfer to align money-laundering proceedings with the connected scheduled offence.
    July 16, 2026   Case Laws Money Laundering
    Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
    July 16, 2026   Case Laws Service Tax
    Pan-India service-tax investigation powers extend beyond local limits, while pre-notice consultation remains recommendatory under departmental guidanc...
    July 16, 2026   Case Laws Service Tax
    Documentary proof of service-tax payment governs refund eligibility, while delayed-refund interest runs only after the statutory waiting period.
    July 16, 2026   Case Laws Wealth-tax
    Specialised agricultural valuation qualifications validly distinguish expertise in land, crop and soil assessment from other professional credentials.
    July 15, 2026   Notifications SEBI
    Alternative investment fund scheme filings now require prescribed documents, faster submission, comment compliance, and a first-scheme fee exemption.
    July 15, 2026   Notifications SEBI
    Securities transfer and transmission procedures now follow SEBI specifications, while specified Schedule VII requirements are removed.
    July 15, 2026   Notifications DGFT
    Forced-labour import prohibition empowers targeted restrictions on goods made wholly or partly through involuntary work.
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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.
July 16, 2026   Case Laws Customs
Reasonable-time limits on duty drawback recovery bar unexplained delayed proceedings where fraud or suppression is not alleged.
July 16, 2026   Case Laws Customs
Specific LCD tariff classification prevails over end-use based controller classification, requiring fresh determination under Chapter 90.
July 16, 2026   Case Laws Customs
Provisional release for re-export remains available pending unresolved classification, despite alleged import restrictions on seized goods.
July 16, 2026   Case Laws Customs
Strict construction of customs exemptions denies ELISA-kit duty concession to separately imported QFT Tube components.
July 16, 2026   Case Laws Customs
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequential relief.
July 16, 2026   Case Laws IBC
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and related show-cause notice.
July 16, 2026   Case Laws IBC
Leasehold BOT rights can be liquidated as going-concern assets while preserving landowner rights and end-of-concession transfer obligations.
July 16, 2026   Case Laws IBC
Contractual development rights may be insolvency assets, but resolution plans cannot override third-party land title or statutory approvals.
July 16, 2026   Case Laws Money Laundering
Territorial jurisdiction under PMLA may be concurrent, allowing transfer to align money-laundering proceedings with the connected scheduled offence.
July 16, 2026   Case Laws Money Laundering
Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitation.
July 16, 2026   Case Laws Service Tax
Pan-India service-tax investigation powers extend beyond local limits, while pre-notice consultation remains recommendatory under departmental guidance.
July 16, 2026   Case Laws Service Tax
Documentary proof of service-tax payment governs refund eligibility, while delayed-refund interest runs only after the statutory waiting period.
July 16, 2026   Case Laws Wealth-tax
Specialised agricultural valuation qualifications validly distinguish expertise in land, crop and soil assessment from other professional credentials.
July 15, 2026   Notifications SEBI
Alternative investment fund scheme filings now require prescribed documents, faster submission, comment compliance, and a first-scheme fee exemption.
July 15, 2026   Notifications SEBI
Securities transfer and transmission procedures now follow SEBI specifications, while specified Schedule VII requirements are removed.
July 15, 2026   Notifications DGFT
Forced-labour import prohibition empowers targeted restrictions on goods made wholly or partly through involuntary work.

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