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    September 28, 2026   Case Laws GST
    Overlapping GST proceedings bar consolidated demands for periods already covered by State tax action and require fresh determination.
    September 28, 2026   Case Laws GST
    Effective service of rectification notices is essential before rejecting inverted-duty GST refunds, requiring fresh hearing on remand.
    September 28, 2026   Case Laws GST
    Erroneous refund recovery permits statutory interest on excess inverted-duty ITC refunds despite unchallenged sanction orders and principal repayment.
    September 28, 2026   Case Laws Income Tax
    Section 132B release requires timely disclosure of seized cash's nature and source; established ownership alone does not compel release.
    September 28, 2026   Case Laws Income Tax
    Change-of-opinion reassessment of employment deduction fails without fresh tangible material, invalidating the reopening process entirely.
    September 28, 2026   Case Laws Income Tax
    Reassessment notices alleging fictitious mutual-fund losses were quashed where a final prior ruling governed identical facts.
    September 28, 2026   Case Laws Income Tax
    Genuine hardship in refund condonation requires reasoned findings on claim correctness and genuineness, not a stand-alone delay explanation.
    September 28, 2026   Case Laws Income Tax
    Tariff-related income-tax reimbursement disputes require specialised regulatory adjudication, leaving contested debit-note merits outside ordinary wri...
    September 28, 2026   Case Laws Income Tax
    Unverified Insight Portal Information Cannot Justify Reassessment Without a Verified Taxpayer-Specific Income-Escape Nexus or Demonstrated Application...
    September 28, 2026   Case Laws Income Tax
    Assessing Officer jurisdiction after statutory transfer invalidates reassessment notices issued by transferor officers and nullifies resulting proceed...
    September 28, 2026   Case Laws Income Tax
    Consequential appeal-effect orders must implement rectification deleting working-capital adjustments and reconsider the resulting arm's-length range c...
    September 28, 2026   Case Laws Income Tax
    DCF valuation choice: Assessing officers cannot replace a valid share valuation method with NAV solely over projections.
    September 28, 2026   Case Laws Income Tax
    Discounted cash flow valuation protects share premium where projections are reasonable, while audited book expenses defeat unexplained-expenditure add...
    September 28, 2026   Case Laws Income Tax
    Time-barred scrutiny notices invalidate assessments, while missing statutory transfer orders deprive the assessing officer of jurisdiction.
    September 28, 2026   Case Laws Income Tax
    Appellate territorial jurisdiction follows the Assessing Officer's location, requiring proceedings only before the appropriate Bench.
    September 28, 2026   Case Laws Income Tax
    Unexplained investment requires proof that the assessee made an unrecorded investment; predecessor liabilities cannot support addition.
    September 28, 2026   Case Laws Income Tax
    Section 54 construction relief survives pre-transfer commencement when completion occurs within the statutory period, excluding ineligible spouse-owne...
    September 28, 2026   Case Laws Income Tax
    Reopening beyond the statutory time limit fails when recorded reasons lack tangible material and disclosures were complete.
    September 28, 2026   Case Laws Income Tax
    Rectification jurisdiction bars evidence reappraisal where alleged on-money additions were previously decided after considering relevant material.
    September 28, 2026   Case Laws Income Tax
    Cash-payment disallowance requires proof of daily payments to one person; additional evidence prompted fresh adjudication.
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September 28, 2026   Case Laws GST
Overlapping GST proceedings bar consolidated demands for periods already covered by State tax action and require fresh determination.
September 28, 2026   Case Laws GST
Effective service of rectification notices is essential before rejecting inverted-duty GST refunds, requiring fresh hearing on remand.
September 28, 2026   Case Laws GST
Erroneous refund recovery permits statutory interest on excess inverted-duty ITC refunds despite unchallenged sanction orders and principal repayment.
September 28, 2026   Case Laws Income Tax
Section 132B release requires timely disclosure of seized cash's nature and source; established ownership alone does not compel release.
September 28, 2026   Case Laws Income Tax
Change-of-opinion reassessment of employment deduction fails without fresh tangible material, invalidating the reopening process entirely.
September 28, 2026   Case Laws Income Tax
Reassessment notices alleging fictitious mutual-fund losses were quashed where a final prior ruling governed identical facts.
September 28, 2026   Case Laws Income Tax
Genuine hardship in refund condonation requires reasoned findings on claim correctness and genuineness, not a stand-alone delay explanation.
September 28, 2026   Case Laws Income Tax
Tariff-related income-tax reimbursement disputes require specialised regulatory adjudication, leaving contested debit-note merits outside ordinary writ jurisdiction for determination.
September 28, 2026   Case Laws Income Tax
Unverified Insight Portal Information Cannot Justify Reassessment Without a Verified Taxpayer-Specific Income-Escape Nexus or Demonstrated Application of Mind
September 28, 2026   Case Laws Income Tax
Assessing Officer jurisdiction after statutory transfer invalidates reassessment notices issued by transferor officers and nullifies resulting proceedings.
September 28, 2026   Case Laws Income Tax
Consequential appeal-effect orders must implement rectification deleting working-capital adjustments and reconsider the resulting arm's-length range claim.
September 28, 2026   Case Laws Income Tax
DCF valuation choice: Assessing officers cannot replace a valid share valuation method with NAV solely over projections.
September 28, 2026   Case Laws Income Tax
Discounted cash flow valuation protects share premium where projections are reasonable, while audited book expenses defeat unexplained-expenditure additions.
September 28, 2026   Case Laws Income Tax
Time-barred scrutiny notices invalidate assessments, while missing statutory transfer orders deprive the assessing officer of jurisdiction.
September 28, 2026   Case Laws Income Tax
Appellate territorial jurisdiction follows the Assessing Officer's location, requiring proceedings only before the appropriate Bench.
September 28, 2026   Case Laws Income Tax
Unexplained investment requires proof that the assessee made an unrecorded investment; predecessor liabilities cannot support addition.
September 28, 2026   Case Laws Income Tax
Section 54 construction relief survives pre-transfer commencement when completion occurs within the statutory period, excluding ineligible spouse-owned land.
September 28, 2026   Case Laws Income Tax
Reopening beyond the statutory time limit fails when recorded reasons lack tangible material and disclosures were complete.
September 28, 2026   Case Laws Income Tax
Rectification jurisdiction bars evidence reappraisal where alleged on-money additions were previously decided after considering relevant material.
September 28, 2026   Case Laws Income Tax
Cash-payment disallowance requires proof of daily payments to one person; additional evidence prompted fresh adjudication.

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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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