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September 29, 2026   Circulars IBC
PGIRP Filing Deadline Extension Defers Penalties for Delayed or Modified Personal Guarantor Insolvency Resolution Process Forms
September 29, 2026   Case Laws Income Tax
Natural justice in transfer pricing requires personal hearings and reasoned consideration of written objections before determinations are made.
September 29, 2026   Case Laws GST
Project-level anti-profiteering methodology treats actual post-GST ITC gains as buyer benefits, including consequential GST and interest.
September 29, 2026   Case Laws GST
Effective GST personal hearings require reply time to expire first; premature scheduling invalidates adjudication and requires fresh proceedings.
September 29, 2026   Case Laws GST
Statutory stay on GST recovery requires review of claimed appellate deposits and refund or recredit of excess recovery.
September 29, 2026   Case Laws GST
GST adjudication limits: demands and penalties cannot exceed the show-cause notice, requiring fresh adjudication when statutory limits are breached.
September 29, 2026   Case Laws GST
Fresh GST adjudication follows claimed tax discharge and overlapping demands, conditional on payment of previously assessed interest and penalties.
September 29, 2026   Case Laws GST
Expired e-way bills alone cannot support detention and penalty where invoices, verification and absence of tax evasion show compliance.
September 29, 2026   Case Laws GST
Mandatory employee canteens: recoveries avoid GST, while input tax credit is limited to the employer-borne cost.
September 29, 2026   Case Laws Income Tax
Clean-slate corporate sales prevent reassessment for extinguished liabilities, while section 148A orders cannot add unnotified allegations.
September 29, 2026   Case Laws Income Tax
Good faith and due diligence under Explanation 7 protect transfer pricing positions involving debatable TNMM application differences.
September 29, 2026   Case Laws Income Tax
Audit-report timing: Form 10B filed within an extended return deadline preserves charitable-trust exemption despite rejected condonation.
September 29, 2026   Case Laws Income Tax
Beneficial ownership of State funds excludes interest taxation, while project-transfer signature bonuses remain business revenue receipts.
September 29, 2026   Case Laws Income Tax
Parallel reassessment on identical search-assessment additions was quashed because it would directly affect pending tax appeals.
September 29, 2026   Case Laws Income Tax
SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are examined.
September 29, 2026   Case Laws Income Tax
Specificity in search-penalty notices is essential: failure to state the applicable charge and rate invalidates the proceedings.
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.

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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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