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    September 1, 2026   Case Laws Income Tax
    Transfer-pricing comparability requires aligned related-party exposure, ownership profile, revenue model and sourcing-support functions to prevent dis...
    September 1, 2026   Case Laws Income Tax
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    TDS on statutory market fees and pass-through procurement payments did not trigger contract withholding disallowance.
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    Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
    September 1, 2026   Case Laws Income Tax
    Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
    September 1, 2026   Case Laws Income Tax
    Misreporting penalties require proven statutory defaults, not merely transfer-pricing adjustments caused by competing benchmarking and comparability m...
    September 1, 2026   Case Laws Income Tax
    Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
    September 1, 2026   Case Laws Income Tax
    Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
    September 1, 2026   Case Laws Income Tax
    TDS liability on foreign-agent commission requires verification of payment figures and Indian taxable presence before fresh adjudication.
    September 1, 2026   Case Laws Income Tax
    Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
    September 1, 2026   Case Laws Income Tax
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September 1, 2026   Case Laws Income Tax
Transfer-pricing comparability requires aligned related-party exposure, ownership profile, revenue model and sourcing-support functions to prevent distorted margins in benchmark analysis.
September 1, 2026   Case Laws Income Tax
Assessment jurisdiction requires valid statutory transfer and timely scrutiny notice; administrative reassignment cannot sustain proceedings.
September 1, 2026   Case Laws Income Tax
TDS on statutory market fees and pass-through procurement payments did not trigger contract withholding disallowance.
September 1, 2026   Case Laws Income Tax
Binding Dispute Resolution Panel directions invalidate non-conforming assessments, while ad hoc nil pricing of intra-group services fails.
September 1, 2026   Case Laws Income Tax
Electronic service of DRP directions triggers assessment limitation, making a belated final assessment time-barred and beyond jurisdiction.
September 1, 2026   Case Laws Income Tax
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export receipts.
September 1, 2026   Case Laws Income Tax
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notional-interest adjustment.
September 1, 2026   Case Laws Income Tax
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and margin findings.
September 1, 2026   Case Laws Income Tax
Misreporting penalties require proven statutory defaults, not merely transfer-pricing adjustments caused by competing benchmarking and comparability methodologies.
September 1, 2026   Case Laws Income Tax
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the statutory limit.
September 1, 2026   Case Laws Income Tax
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings were quashed.
September 1, 2026   Case Laws Income Tax
TDS liability on foreign-agent commission requires verification of payment figures and Indian taxable presence before fresh adjudication.
September 1, 2026   Case Laws Income Tax
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-capital adjustments require verification.
September 1, 2026   Case Laws Income Tax
Maintainability of revision-order appeals depends on grounds showing a grievance against revision, otherwise dismissal follows independently.
September 1, 2026   Case Laws Customs
Related-party customs valuation requires objective doubt, while royalties not conditional on imported goods' sale remain excluded.
September 1, 2026   Case Laws Customs
Specific drugs-and-medicines classification gives eligible bulk drugs and APIs concessional IGST treatment despite chemical tariff classification.
September 1, 2026   Case Laws Customs
Specific drug-rate entry covers imported APIs and bulk drugs, overriding general chemical chapter entries for concessional IGST treatment.
September 1, 2026   Case Laws Companies Law
Annual accounts for companies in liquidation remain mandatory despite filed half-yearly audited accounts, preserving accurate financial disclosure.
September 1, 2026   Case Laws SEBI
Suppression of prior proceedings in PIL jurisdiction resulted in dismissal for forum shopping and abuse of process.
September 1, 2026   Case Laws IBC
Forfeiture of an auction deposit before an extended payment period expires is arbitrary and requires refund without interest.

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Income Tax

Addition u/s 56(2)(viib) - issue of shares at premium -...

Section 56(2)(viib) and Fair Market Value: Share Premium Valuation via DCF Requires Certification by Experts, Not Adjusted by Assessing Officer.

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Income Tax July 11, 2023 Case Laws AT
Addition u/s 56(2)(viib) - issue of shares at premium - Determination of fair market value - The very purpose of certification of DCF valuation by a merchant banker or chartered accountant is to ensure that the valuation is fair and reasonable. Such valuation is to be done by an expert of the subject only, which an assessing officer is not expected to be. The said rule provides that such valuation shall be the fair market value for the purpose of this section based on DCF Method. The Rule nowhere permits the AO to make any adjustment therein. - AT
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Acts Income Tax
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