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    September 30, 2026   Case Laws Income Tax
    Reassessment limitation excludes section 148A response time; Indian support-services affiliate does not create a dependent agent PE.
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September 30, 2026   Case Laws Income Tax
Reassessment limitation excludes section 148A response time; Indian support-services affiliate does not create a dependent agent PE.
September 30, 2026   Case Laws Income Tax
Dependent-agent permanent establishment requires proof of actual contractual authority; liaison and support functions alone do not suffice.
September 30, 2026   Case Laws Income Tax
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pricing.
September 30, 2026   Case Laws Income Tax
Goodwill in a slump sale qualifies for depreciation when the transferred business includes its operating intangible assets.
September 30, 2026   Case Laws Income Tax
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA.
September 30, 2026   Case Laws Income Tax
Extinguishment of specific-performance rights permits capital-gains deduction when payment clears title and enables property transfer.
September 30, 2026   Case Laws Customs
Excess baggage jewellery detention permits return application and consensual minor penalty for admitted Customs Baggage Rules infraction.
September 30, 2026   Case Laws Customs
Duty drawback survives RBI-backed rupee export remittances and completed exports despite alleged diversion to intermediary ports.
September 30, 2026   Case Laws Customs
Statutory notice period for seized goods requires release when notice is absent; provisional release cannot preserve detention.
September 30, 2026   Case Laws Customs
Customs adjudication evidence rules bar uncross-examined Section 108 statements and uncertified electronic records, defeating unsupported abetment penalties.
September 30, 2026   Case Laws Customs
Customs broker abetment requires proof of knowledge, collusion or active assistance, not merely alleged IEC verification failure.
September 30, 2026   Case Laws Customs
Formulated astaxanthin preparations qualify as food preparations where nutritional function predominates and colour remains incidental to dietary use.
September 30, 2026   Case Laws Companies Law
Consent terms in oppression proceedings bind parties and can resolve appellate challenges without merits adjudication, quashing contested findings.
September 30, 2026   Case Laws IBC
One-time settlement during liquidation does not change statutory distribution, and guarantors gain no creditor priority without debt assignment.
September 30, 2026   Case Laws IBC
CoC-approved eligibility criteria must precede Form G, while expired CIRP without a resolution plan requires liquidation.
September 30, 2026   Case Laws FEMA
FEMA borrowing restrictions bind charitable trusts, and civil penalties apply without proving intent for delayed repayment of non-resident rupee loans.
September 30, 2026   Case Laws Money Laundering
Property-attachment appeal documents relevant to continuing attachment must be admitted, while costs survive for belated production.
September 30, 2026   Case Laws Money Laundering
PMLA property retention permits prima facie proceeds-of-crime inquiry beyond accused ownership, absent prejudice from defective notice service.
September 30, 2026   Case Laws Central Excise
Excise manufacture test for modified vehicles requires fresh findings; intentional suppression alone permits extended limitation and penalties.
September 30, 2026   Case Laws Companies Law
Oral corporate agreements remain valid where no statutory writing requirement applies; disputed representative authority requires evidence, not threshold rejection.

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Home › Highlights › Income Tax › 2023 › January, 2023 › This
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Income Tax

TP adjustment - Design Engineering Services - Selection of...

Company Excluded as Comparable in Transfer Pricing Case Due to High Software Revenue and Lack of Segmental Data.

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Income Tax January 25, 2023 Case Laws AT
TP adjustment - Design Engineering Services - Selection of comparable - Since the assessee is not providing any Software services and the software services of this company constitute around 78% of its revenue and further that no segmental information is available, we hold that this company cannot be treated as comparable. We, therefore, order to exclude it from the list of comparables. - AT
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