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    October 8, 2026   Notes Income Tax
    Genuine Hardship in Delayed Revised Returns Requires Condonation Review Before Independent Examination of Exemption and Refund Claims
    October 8, 2026   Notes Income Tax
    Verified TDS deduction protects domestic taxpayers from denied credit, refund adjustment, and duplicate recovery despite deductor default.
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October 8, 2026   Notes Income Tax
Genuine Hardship in Delayed Revised Returns Requires Condonation Review Before Independent Examination of Exemption and Refund Claims
October 8, 2026   Notes Income Tax
Verified TDS deduction protects domestic taxpayers from denied credit, refund adjustment, and duplicate recovery despite deductor default.
October 8, 2026   Notes Indian Laws
Timely pronouncement of reserved judgments requires defined timelines, transparency measures, and remedial pathways to protect liberty and effective justice.
October 8, 2026   Notes SEBI
Settlement-price depression requires proof of manipulation, not merely short exposure, late selling, or below-market orders, preserving disclosure penalties.
October 8, 2026   Notes Income Tax
Foreign LTC tax treatment requires TDS on known non-exempt travel claims despite recovery-related interim relief.
October 8, 2026   Notes GST
Extended GST limitation requires a notice to plead fraud, wilful misstatement or suppression with supporting factual particulars.
October 8, 2026   Circulars SEBI
Merchant banker appointment exemption permits eligible regulated listed issuers to privately place highly rated debt without appointing one.
October 8, 2026   Circulars Central Excise
Reassignment of pending legacy indirect-tax appeals directs listed matters to designated appellate Commissioners for Orders-in-Appeal.
October 8, 2026   Circulars Customs
Export Declaration Form authentication at Non-EDI Customs locations requires secure electronic forwarding to the designated Authorised Dealer.
October 8, 2026   Circulars Customs
Customs area declaration enables O Yard CFS to handle Kamarajar Port import, baggage and export cargo under prescribed procedures.
October 8, 2026   Circulars Customs
Customs custody appointment extends O Yard CFS responsibility to imports and exports routed through Kamarajar Port.
October 8, 2026   Case Laws GST
Electronic GST authentication validates portal-issued demand notices, while portal upload starts limitation and RFN can replace DIN.
October 8, 2026   Case Laws GST
Assessment of unregistered persons must precede GST recovery proceedings, leaving educational institution exemption claims open for determination.
October 8, 2026   Case Laws Customs
Revised customs prosecution thresholds can govern pending gold-smuggling complaints, requiring reconsideration of withdrawal despite prior prosecution sanction.
October 8, 2026   Case Laws GST
Leasehold rights assignments in industrial plots remain outside GST where treated as benefits arising from immovable property.
October 8, 2026   Case Laws GST
Pre-deposit timing turns on final acknowledgement, allowing a timely defect cure before appeal registration and merits consideration.
October 8, 2026   Case Laws FEMA
Proportionality review restricts reduction of FERA penalties unless the sanction is grossly excessive, unduly harsh, or conscience-shocking.
October 8, 2026   Case Laws Income Tax
Offshore supply receipts remain outside Indian taxation where CIF title passes abroad and contracts are genuinely separate.
October 8, 2026   Case Laws Income Tax
Income Declaration Scheme declarations can evidence share-capital sources, while round-tripped funds and cash-linked credits require further verification.
October 8, 2026   Case Laws Income Tax
Business set-up versus commencement determines deductibility, while appellate findings require consideration of contemporaneous operational evidence.

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

TP Adjustment - ALP determination - interest received on...

Interest on Outbound Loans to Use LIBOR, Not PLR, for Arm's Length Price, Says Transfer Pricing Officer.

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Income Tax February 7, 2023 Case Laws AT
TP Adjustment - ALP determination - interest received on outbound loans - LIBOR v/s PLR - the prevailing LIBOR rate should be adopted for the interest received on outbound loans. We therefore direct the Ld. TPO to calculate the interest as per the prevailing LIBOR rates. - AT
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