Loading...

⚠ ✕
❮ Top
☎ Help
☰
GST ▸
Central GST ▸
Integrated GST + ▸
UTGST / SGST ▸
GST Case Laws + ▸
Income Tax ▸
Income Tax ▸
Allied (Direct Tax) ▸
Income Tax Case Laws ▸
DTAA ▸
International Taxation ▸
Customs ▸
Customs Act / Rules ▸
Notifications / Forms ▸
Circulars / Tariff ▸
Case Laws / Manual ▸
FTP/SEZ ▸
Foreign Trade ▸
Notifications / Circulars / Appendix / Forms ▸
Special Economic Zone (SEZ) ▸
Corp. Law ▸
Company Laws ▸
Standards / Trusts ▸
Partnership / LLP / Societies ▸
Case Laws ▸
FEMA ▸
FEMA / FCRA ▸
Notifications / Circulars ▸
Manual / FAQ ▸
FEMA Case Laws ▸
SEBI / IBC ▸
SEBI ▸
SEBI Case Laws ▸
IBC ▸
IBC - Case Laws ▸
PMLA ▸
Benami Property ▸
Black Money ▸
Money Laundering ▸
Vivad ▸
Direct Tax ▸
Indirect Taxes ▸
Indian Laws ▸
Indian Laws ▸
Bharatiya Nyaya 2023 ▸
Finance Acts & Bills / Amendment Acts ▸
Case Laws ▸
Labour Laws ▸
Labour Code ▸
Old / Others ▸
Central Excise ▸
Central Excise - Cases ▸
Wealth Tax ▸
Service Tax ▸
Service Tax Cases ▸
CST / DVAT ▸
CST / VAT / Sales Tax ▸
×

By creating an account you can:

Logo TaxTMI
Keyword Search :
AI Tools : New
Ask tax questions in natural language. Powered by AI trained on the TaxTMI legal database. Use AI Tools ➞
Call Us / Help / Feedback✕

Contact Us At :

✉ E-mail: [email protected]

✆ Call / WhatsApp at: +91 99117 96707

For more information, Check Contact Us

FAQs :

To know Frequently Asked Questions, Check FAQs

Most Asked Video Tutorials :

For more tutorials, Check Video Tutorials

Submit Feedback/Suggestion :

Email :
Please provide your email address so we can follow up on your feedback.
Category :
Description :
Min 15 characters 0/2000
Make Most of Text Search ✕
  1. Checkout this video tutorial: How to search effectively on TaxTMI.
  2. Put words in double quotes for exact word search, eg: "income tax"
  3. Avoid noise words such as : 'and, of, the, a'
  4. Sort by Relevance to get the most relevant document.
  5. Press Enter to add multiple terms/multiple phrases, and then click on Search to Search.
    6. Text Search
  6. The system will try to fetch results that contains ALL your words.
  7. Once you add keywords, you'll see a new 'Search In' filter that makes your results even more precise.
    8. Text Search
╳
Add to...
You have not created any category. Kindly create one to bookmark this item!
✕
Create New Category
Hide
Title :
Description :
❮❮ Hide
❮ Default View
Expand ❯❯
Close ✕
🔎 Filters / Advanced Search ❯
TEXT

Press 'Enter' to add multiple search terms. Rules for Better Search

Search In
Main Text + AI Text ❯
  • Main Text
  • Main Text + AI Text
  • AI Text
Law:
---- All Laws---- ❯
  • ---- All Laws----
  • Income Tax
  • Direct Taxes
  • Benami Property
  • Central GST Laws
  • SGST - State GST Laws
  • Customs
  • FTP - Foreign Trade Policy
  • SEZ - Special Economic Zone
  • FEMA - Foreign Exchange Management
  • Companies Law
  • SEBI - Securities & Exchange Board of India
  • IBC - Insolvency and Bankruptcy
  • Law of Competition
  • PMLA - Money-Laundering
  • Indian Laws
  • Bill / Finance Bills
  • Wealth Tax
  • Service Tax
  • Central Excise
  • VAT / Sales Tax
Month:
---- All Months ---- ❯
  • ---- All Months ----
  • January
  • February
  • March
  • April
  • May
  • June
  • July
  • August
  • September
  • October
  • November
  • December
Year:
---- All Years ---- ❯
  • ---- All Years ----
  • 2026
  • 2025
  • 2024
  • 2023
  • 2022
  • 2021
  • 2020
  • 2019
  • 2018
  • 2017
  • 2016
  • 2015
  • 2014
  • 2013
  • 2012
  • 2011
Sort By: ?
In Sort By 'Default', exact matches for text search are shown at the top, followed by the remaining results in their regular order.
Relevance Default Date
☰   Show Results ❯
    September 26, 2026   Case Laws GST
    Agglomerated cork classification permits concessional GST treatment, while inverted-duty refund eligibility remains outside advance-ruling jurisdictio...
    September 26, 2026   Case Laws Income Tax
    Change of opinion bars reassessment when original scrutiny examined claims and no fresh tangible material emerges.
    September 26, 2026   Case Laws Income Tax
    Search-assessment limitation requires stay exclusions before TOLA extension, rendering delayed assessments and consequential penalties time-barred.
    September 26, 2026   Case Laws Income Tax
    Change of opinion bars reassessment where audit-report misreading incorrectly treats salary-tax withholding as a claimed deduction.
    September 26, 2026   Case Laws Income Tax
    Tax deduction on defective-product rebates fails where uniform credit notes are not consideration for distributor repair work.
    September 26, 2026   Case Laws Income Tax
    Capital-gains exemption for charitable trusts extends to qualifying fixed deposits, while unrecoverable TDS write-offs may constitute income applicati...
    September 26, 2026   Case Laws Income Tax
    India-UK treaty characterisation of telecom-service receipts as business profits withstands unilateral domestic-law amendments for Indian tax purposes...
    September 26, 2026   Case Laws Income Tax
    Specific statutory charge for misreporting is essential; appellate proceedings cannot recast it as ordinary under-reporting penalty.
    September 26, 2026   Case Laws Income Tax
    Ad hoc expense disallowances fail without identified accounting defects; explained cash sales cannot be taxed twice.
    September 26, 2026   Case Laws Income Tax
    Corporate guarantees as international transactions require arm's-length pricing, while related fees cannot qualify for SEZ development deductions.
    September 26, 2026   Case Laws Income Tax
    Business expenditure deductions for director insurance premiums fail where policy benefits vest personally in directors, not the company.
    September 26, 2026   Case Laws Income Tax
    Transfer-pricing reimbursement adjustments require uncontrolled comparables and cannot become expense-genuineness reviews, resulting in deletion of th...
    September 26, 2026   Case Laws Income Tax
    Compulsory acquisition compensation for rural agricultural land remains exempt from income tax, preventing short-term capital-gain treatment.
    September 26, 2026   Case Laws Income Tax
    Recorded cash sales during demonetisation cannot be taxed twice when books and stock records are accepted.
    September 26, 2026   Case Laws Income Tax
    Market data and secondment reimbursements: associated-enterprise recoveries were not taxable as royalty, included services, or technical services.
    September 26, 2026   Case Laws Income Tax
    Embedded Profit in Bogus Diamond Purchases Limits Additions Where Sales, Stock Records and Books Remain Accepted
    September 26, 2026   Case Laws Income Tax
    Reassessment jurisdiction requires recorded reasons to maintain a rational live nexus with the income ultimately assessed.
    September 26, 2026   Case Laws Income Tax
    Discounted cash flow valuation protects the taxpayer's chosen share-premium valuation method from unsupported net asset value substitution.
    September 26, 2026   Case Laws Customs
    Ninety-day limitation for Customs Broker licence revocation bars delayed notices and requires restoration where the deadline is missed.
    September 26, 2026   Case Laws Customs
    Section 50 safeguards require an independent search choice, while prolonged NDPS detention may justify bail despite prima facie evidence.
❮
❯
❯❯
Maximize Maximize Maximize
0 / 200
Expand Note
Add to Folder

No Folders have been created

+

Are you sure you want to delete "My most important" ?

NOTE:

Open Link
Highlights
Showing Results for :
Reset Filters
Results Found:
Show All Summaries Hide All Summaries
September 26, 2026   Case Laws GST
Agglomerated cork classification permits concessional GST treatment, while inverted-duty refund eligibility remains outside advance-ruling jurisdiction.
September 26, 2026   Case Laws Income Tax
Change of opinion bars reassessment when original scrutiny examined claims and no fresh tangible material emerges.
September 26, 2026   Case Laws Income Tax
Search-assessment limitation requires stay exclusions before TOLA extension, rendering delayed assessments and consequential penalties time-barred.
September 26, 2026   Case Laws Income Tax
Change of opinion bars reassessment where audit-report misreading incorrectly treats salary-tax withholding as a claimed deduction.
September 26, 2026   Case Laws Income Tax
Tax deduction on defective-product rebates fails where uniform credit notes are not consideration for distributor repair work.
September 26, 2026   Case Laws Income Tax
Capital-gains exemption for charitable trusts extends to qualifying fixed deposits, while unrecoverable TDS write-offs may constitute income application.
September 26, 2026   Case Laws Income Tax
India-UK treaty characterisation of telecom-service receipts as business profits withstands unilateral domestic-law amendments for Indian tax purposes.
September 26, 2026   Case Laws Income Tax
Specific statutory charge for misreporting is essential; appellate proceedings cannot recast it as ordinary under-reporting penalty.
September 26, 2026   Case Laws Income Tax
Ad hoc expense disallowances fail without identified accounting defects; explained cash sales cannot be taxed twice.
September 26, 2026   Case Laws Income Tax
Corporate guarantees as international transactions require arm's-length pricing, while related fees cannot qualify for SEZ development deductions.
September 26, 2026   Case Laws Income Tax
Business expenditure deductions for director insurance premiums fail where policy benefits vest personally in directors, not the company.
September 26, 2026   Case Laws Income Tax
Transfer-pricing reimbursement adjustments require uncontrolled comparables and cannot become expense-genuineness reviews, resulting in deletion of the adjustment.
September 26, 2026   Case Laws Income Tax
Compulsory acquisition compensation for rural agricultural land remains exempt from income tax, preventing short-term capital-gain treatment.
September 26, 2026   Case Laws Income Tax
Recorded cash sales during demonetisation cannot be taxed twice when books and stock records are accepted.
September 26, 2026   Case Laws Income Tax
Market data and secondment reimbursements: associated-enterprise recoveries were not taxable as royalty, included services, or technical services.
September 26, 2026   Case Laws Income Tax
Embedded Profit in Bogus Diamond Purchases Limits Additions Where Sales, Stock Records and Books Remain Accepted
September 26, 2026   Case Laws Income Tax
Reassessment jurisdiction requires recorded reasons to maintain a rational live nexus with the income ultimately assessed.
September 26, 2026   Case Laws Income Tax
Discounted cash flow valuation protects the taxpayer's chosen share-premium valuation method from unsupported net asset value substitution.
September 26, 2026   Case Laws Customs
Ninety-day limitation for Customs Broker licence revocation bars delayed notices and requires restoration where the deadline is missed.
September 26, 2026   Case Laws Customs
Section 50 safeguards require an independent search choice, while prolonged NDPS detention may justify bail despite prima facie evidence.

Highlights

Back

All Highlights

Showing Results for :
Reset Filters
No Records Found

Highlights

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

All Highlights

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.

Contents
Summary
Note

Note

-

Bookmark

Print

Print

Print Options

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
View Source View

Topics

Acts Income Tax
Next ➔