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    September 29, 2026   Case Laws Income Tax
    Inadequate TDS inquiry into commission expenditure can justify revision where material discrepancies remain unexplained after generic verification.
    September 29, 2026   Case Laws Income Tax
    Ad Hoc Disallowance of Livestock Purchases Fails Without Identified Defects or Evidence of Non-Genuine Transactions.
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    Section 69A Addition: Income included in taxable income but omitted from return schedule, alongside appeal-limitation exclusion.
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    September 29, 2026   Case Laws Income Tax
    Source-of-source burden shifts to Revenue after cash-gift donors' identity, genuineness, and basic creditworthiness are established.
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    Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
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    Evidentiary substantiation in assessments: unsupported cash deposits, land-facilitation receipts, and GST sales supported additions and business-incom...
    September 29, 2026   Case Laws Income Tax
    Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
    September 29, 2026   Case Laws Income Tax
    Redevelopment hardship compensation is capital, while gross salary reporting alone cannot determine taxability or defeat evidenced deductions.
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    Treaty-rate dividend tax refund claim remitted pending larger Bench ruling; commercially expedient media research expenditure remained deductible.
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    Online gaming winnings: Skill-based prizes remain taxable, but only real net gains may be assessed
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    MEIS eligibility survives an inadvertent electronic shipping-bill declaration error where genuine exports and reward-claim intent are established.
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    Premature EPCG export-obligation demands do not bar Revenue from re-verifying IGST credit data and deciding lawfully
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    Section 112(a) penalty fails where alleged misclassification lacks confiscation basis and related importer demand has been set aside.
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    September 29, 2026   Case Laws Companies Law
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    September 29, 2026   Case Laws Companies Law
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September 29, 2026   Case Laws Income Tax
Inadequate TDS inquiry into commission expenditure can justify revision where material discrepancies remain unexplained after generic verification.
September 29, 2026   Case Laws Income Tax
Ad Hoc Disallowance of Livestock Purchases Fails Without Identified Defects or Evidence of Non-Genuine Transactions.
September 29, 2026   Case Laws Income Tax
Section 69A Addition: Income included in taxable income but omitted from return schedule, alongside appeal-limitation exclusion.
September 29, 2026   Case Laws Income Tax
Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreements.
September 29, 2026   Case Laws Income Tax
Reassessment limitation excludes the section 148A(b) response period, while political donation deductions require proof beyond banking records.
September 29, 2026   Case Laws Income Tax
Source-of-source burden shifts to Revenue after cash-gift donors' identity, genuineness, and basic creditworthiness are established.
September 29, 2026   Case Laws Income Tax
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investments.
September 29, 2026   Case Laws Income Tax
Evidentiary substantiation in assessments: unsupported cash deposits, land-facilitation receipts, and GST sales supported additions and business-income treatment.
September 29, 2026   Case Laws Income Tax
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for transfer-pricing purposes.
September 29, 2026   Case Laws Income Tax
Redevelopment hardship compensation is capital, while gross salary reporting alone cannot determine taxability or defeat evidenced deductions.
September 29, 2026   Case Laws Income Tax
Treaty-rate dividend tax refund claim remitted pending larger Bench ruling; commercially expedient media research expenditure remained deductible.
September 29, 2026   Case Laws Income Tax
Online gaming winnings: Skill-based prizes remain taxable, but only real net gains may be assessed
September 29, 2026   Case Laws Customs
Interest on redemption-related customs duty runs only from adjudicated liability, permitting limited writ review despite an alternative remedy.
September 29, 2026   Case Laws Customs
MEIS eligibility survives an inadvertent electronic shipping-bill declaration error where genuine exports and reward-claim intent are established.
September 29, 2026   Case Laws Customs
Premature EPCG export-obligation demands do not bar Revenue from re-verifying IGST credit data and deciding lawfully
September 29, 2026   Case Laws Customs
Section 112(a) penalty fails where alleged misclassification lacks confiscation basis and related importer demand has been set aside.
September 29, 2026   Case Laws Customs
Customs Exemption Conditions Require Pavers to Meet Prescribed Width at Import, Upholding Duty Recovery for Misdeclaration
September 29, 2026   Case Laws Customs
Burden of proving smuggled character of non-notified goods defeats confiscation and consequential penalties where Revenue lacks evidence.
September 29, 2026   Case Laws Companies Law
Nominee director protection shields independent financial-institution appointees from criminal liability where they lack involvement in deposit defaults.
September 29, 2026   Case Laws Companies Law
Reasoned adjudication in oppression disputes requires findings on restructuring allegations; unsupported perjury directions require fair notice and reasons.

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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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