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    August 12, 2026   Case Laws GST
    Fresh GST proceedings after quashed notices remain within limitation, but prejudged show cause notices require neutral reissuance.
    August 12, 2026   Case Laws GST
    Proper officer jurisdiction for a combined GST demand supports one waiver application covering operations across multiple States.
    August 12, 2026   Case Laws GST
    Duplicate GST assessment orders for the same return mismatch cannot coexist; earlier assessment remanded subject to tax payment.
    August 12, 2026   Case Laws GST
    GST amnesty waiver covers self-assessed tax determined under Section 73, while Rule 164 deadlines and approval safeguards remain mandatory.
    August 12, 2026   Case Laws GST
    Distinct legal entity principle bars GST recovery from company bank accounts for deceased proprietor's unpaid dues.
    August 12, 2026   Case Laws GST
    Export turnover mismatches require documentary substantiation and a meaningful opportunity before ex parte GST adjudication is finally sustained.
    August 12, 2026   Case Laws GST
    Communication date for limitation follows the dealer's unrebutted declaration, requiring fresh consideration of the dismissed statutory appeal.
    August 12, 2026   Case Laws Income Tax
    Mandatory settlement limitation period runs from first Interim Board allotment; administrative transfers cannot revive expired disposal time.
    August 12, 2026   Case Laws Income Tax
    Identity-theft defences do not bar reassessment, but Revenue must prove disputed transactions through primary evidence during proceedings.
    August 12, 2026   Case Laws Income Tax
    Discounted Cash Flow valuation for newly incorporated companies was accepted despite later notification under the prescribed valuation rule.
    August 12, 2026   Case Laws Income Tax
    Internal CUP method upheld for project-office transactions where contract risks, rewards and revenue were fully attributed to India.
    August 12, 2026   Case Laws Income Tax
    Revisional relief for double taxation requires merits review where the same income is assessed in two different years.
    August 12, 2026   Case Laws Income Tax
    Charitable registration turns on predominant purpose and genuine activities, while incidental fees and related-party rent require supporting adverse m...
    August 12, 2026   Case Laws Income Tax
    MAT book-profit adjustments exclude disallowances for exempt-income expenditure and demerger expenditure unless expressly listed under the statutory c...
    August 12, 2026   Case Laws Income Tax
    CSR donation deductions and treaty-limited dividend tax support relief for eligible contributions and UK shareholder distributions.
    August 12, 2026   Case Laws Income Tax
    TDS non-deduction under binding interim directions does not make an employer-bank an assessee in default.
    August 12, 2026   Case Laws Income Tax
    Reassessment based on search and independent enquiry sustained, while unverifiable purchases were limited to the estimated profit element.
    August 12, 2026   Case Laws Income Tax
    Reasonable cause for cash land-transaction receipts and repayments supported deletion of penalties for statutory cash-payment breaches.
    August 12, 2026   Case Laws Income Tax
    Specific misreporting charge under section 270A is mandatory; failure to identify the statutory limb invalidates enhanced penalty.
    August 12, 2026   Case Laws Income Tax
    Assessment quashing extinguishes linked cash-loan penalty, while limitation runs from the Assessing Officer's recorded initiation.
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August 12, 2026   Case Laws GST
Fresh GST proceedings after quashed notices remain within limitation, but prejudged show cause notices require neutral reissuance.
August 12, 2026   Case Laws GST
Proper officer jurisdiction for a combined GST demand supports one waiver application covering operations across multiple States.
August 12, 2026   Case Laws GST
Duplicate GST assessment orders for the same return mismatch cannot coexist; earlier assessment remanded subject to tax payment.
August 12, 2026   Case Laws GST
GST amnesty waiver covers self-assessed tax determined under Section 73, while Rule 164 deadlines and approval safeguards remain mandatory.
August 12, 2026   Case Laws GST
Distinct legal entity principle bars GST recovery from company bank accounts for deceased proprietor's unpaid dues.
August 12, 2026   Case Laws GST
Export turnover mismatches require documentary substantiation and a meaningful opportunity before ex parte GST adjudication is finally sustained.
August 12, 2026   Case Laws GST
Communication date for limitation follows the dealer's unrebutted declaration, requiring fresh consideration of the dismissed statutory appeal.
August 12, 2026   Case Laws Income Tax
Mandatory settlement limitation period runs from first Interim Board allotment; administrative transfers cannot revive expired disposal time.
August 12, 2026   Case Laws Income Tax
Identity-theft defences do not bar reassessment, but Revenue must prove disputed transactions through primary evidence during proceedings.
August 12, 2026   Case Laws Income Tax
Discounted Cash Flow valuation for newly incorporated companies was accepted despite later notification under the prescribed valuation rule.
August 12, 2026   Case Laws Income Tax
Internal CUP method upheld for project-office transactions where contract risks, rewards and revenue were fully attributed to India.
August 12, 2026   Case Laws Income Tax
Revisional relief for double taxation requires merits review where the same income is assessed in two different years.
August 12, 2026   Case Laws Income Tax
Charitable registration turns on predominant purpose and genuine activities, while incidental fees and related-party rent require supporting adverse material.
August 12, 2026   Case Laws Income Tax
MAT book-profit adjustments exclude disallowances for exempt-income expenditure and demerger expenditure unless expressly listed under the statutory computation rules.
August 12, 2026   Case Laws Income Tax
CSR donation deductions and treaty-limited dividend tax support relief for eligible contributions and UK shareholder distributions.
August 12, 2026   Case Laws Income Tax
TDS non-deduction under binding interim directions does not make an employer-bank an assessee in default.
August 12, 2026   Case Laws Income Tax
Reassessment based on search and independent enquiry sustained, while unverifiable purchases were limited to the estimated profit element.
August 12, 2026   Case Laws Income Tax
Reasonable cause for cash land-transaction receipts and repayments supported deletion of penalties for statutory cash-payment breaches.
August 12, 2026   Case Laws Income Tax
Specific misreporting charge under section 270A is mandatory; failure to identify the statutory limb invalidates enhanced penalty.
August 12, 2026   Case Laws Income Tax
Assessment quashing extinguishes linked cash-loan penalty, while limitation runs from the Assessing Officer's recorded initiation.

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Income Tax

TDS u/s 195 - Disallowance u/s 40(a)(ia) - non-deduction of TDS...

No TDS liability for management fees u/s 40(a)(ia) as no technical knowledge transfer occurred.

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Income Tax February 8, 2023 Case Laws AT
TDS u/s 195 - Disallowance u/s 40(a)(ia) - non-deduction of TDS on payment of management fees - It is not even the allegation of the revenue that the non-residents had made available to the assessee, the knowledge generated in the course of rendering managerial services. In our view the services rendered were purely managerial services and by no stretch of imagination can be considered as making available any technical knowledge, experience, skill, know-how or processes, to the assessee. - No TDS liability - AT
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Acts Income Tax
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