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October 1, 2026   Case Laws Income Tax
Reasonable cause for non-filing of a return supported deletion of salary-income misreporting penalty despite tax deducted at source.
October 1, 2026   Case Laws Income Tax
Treaty employment income exemption protects Vietnam-earned salary despite Indian payroll, bank receipt, and tax withholding.
October 1, 2026   Case Laws Customs
Prospective operation of exemption notifications prevents later amendments from blocking provisional release of pre-amendment imported machinery.
October 1, 2026   Case Laws Service Tax
Sabka Vishwas discharge certificates remain available where timely payment and appeal withdrawal are completed despite delayed procedural intimation.
October 1, 2026   Case Laws Customs
DGFT regularisation of EPCG imports removes confiscation and penalty, while duty foregone follows Bill of Entry assessable value.
October 1, 2026   Case Laws GST
GST Show Cause Notices Initiate Adjudication, Leaving Audit and Limitation Objections for Statutory Determination Rather Than Writ Intervention
October 1, 2026   Case Laws GST
GST penalty liability for fraudulent invoices reaches non-taxable beneficiaries only upon proof of benefit retention and transaction instigation.
October 1, 2026   Case Laws GST
Hookah service in designated smoking areas remains prohibited despite self-service or rental models under tobacco-control rules.
October 1, 2026   Case Laws GST
Input tax credit on fresh IPO issue expenses is available when proceeds further the company's business activities.
October 1, 2026   Case Laws Income Tax
Erroneous PAN Mapping Invalidates Reassessment Based on Another Person's Share Transaction and Prevents Limitation Avoidance
October 1, 2026   Case Laws Income Tax
Notional interest on delayed associated-enterprise receivables may require no separate adjustment where the taxpayer is entirely debt-free.
October 1, 2026   Case Laws Income Tax
Third-Party Search Material Cannot Extend Reassessment Limitation Where the Applicable Search Assessment Block Has Expired.
October 1, 2026   Case Laws Income Tax
Search penalty requires statutory undisclosed-income finding, precise default notice, and timely completion after assessment appeal.
October 1, 2026   Case Laws Income Tax
Transfer-pricing aggregation of distinct support-service and subcontract transactions was rejected, while debt-free receivables attracted no notional interest.
October 1, 2026   Case Laws Income Tax
Additional evidence and verification govern disputed creditor balances, agricultural claims, sales rebates, and share application money taxability.
October 1, 2026   Case Laws Income Tax
Transfer-pricing tolerance band applies to a single-value internal comparable, treating the declared price as arm's length.
October 1, 2026   Case Laws Income Tax
Pecuniary jurisdiction governs scrutiny notices: an ACIT notice without transfer can invalidate the resulting assessment.
October 1, 2026   Case Laws Customs
Customs exemptions cover photovoltaic assembly machinery and PVF backsheets, while fully declared cleared imports may avoid confiscation and penalties.
October 1, 2026   Case Laws Customs
Specific tariff classification for LCD devices overrides treatment as electricity-meter parts, defeating differential duty, extended limitation, and penalties.
October 1, 2026   Case Laws IBC
Stayed disciplinary punishment does not establish unfitness for insolvency professional registration; reconsideration must disregard mere pendency of disciplinary proceedings.

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

Income deemed to accrue or arise in India - business connection...

Assessing Officer to Verify Income Attribution for Business Connection or PE in India for 2015-16 Tax Year.

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Income Tax June 9, 2023 Case Laws AT
Income deemed to accrue or arise in India - business connection in India - Permanent Establishment (PE) in India - As assessee submits that during the assessment year under consideration i.e. AY 2015-16 also if the attribution rate to the alleged PE is considered at 15% of gross booking fees since India related expenses are more than the attributed gross booking fees to the PE in India it would extinguish the assessment as no further income would be taxable in India. - AO directed to check the correctness of the figures before giving effect to this order. - AT
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Acts Income Tax
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