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    April 2, 2026   Case Laws Income Tax
    Underwriting commission to a non-resident was not fees for technical services because no technical knowledge was made available.
    April 2, 2026   Case Laws Income Tax
    Arm's length interest on inter-company loans cannot be raised solely for unsecured subsidiary lending where no fresh risk change is shown.
    April 2, 2026   Case Laws Income Tax
    Transfer pricing comparability challenge rejected where Revenue sought first-time exclusion of an accepted comparable before the Tribunal.
    April 2, 2026   Case Laws Income Tax
    Transfer pricing, TDS and revenue expense issues resolved by following earlier rulings in recurring group-company disputes.
    April 2, 2026   Case Laws Income Tax
    Contract expenditure allowed where unrebutted documentary evidence proved subcontract payments and supported the corresponding income claim.
    April 2, 2026   Case Laws Income Tax
    Liberal construction of sufficient cause justifies condonation of inordinate delay where criminal proceedings and jail confinement explained the defau...
    April 2, 2026   Case Laws Income Tax
    Penalty under section 272A(1)(d) deleted after quantum proceedings were restored and the assessee's conduct was considered.
    April 2, 2026   Case Laws Income Tax
    Debatable provident fund adjustment cannot be made under prima facie processing when jurisdictional precedent favours the assessee.
    April 2, 2026   Case Laws Income Tax
    Public-domain data access and marketing support services failed royalty and make-available tests under the India-US DTAA.
    April 2, 2026   Case Laws Income Tax
    Taxability of buy-back interest depends on actual receipt and proof that premium or interest was income in the assessee's hands.
    April 2, 2026   Case Laws Income Tax
    Unexplained investment addition deleted where only third-party material existed and no corroborative evidence linked the assessee to on-money payment.
    April 2, 2026   Case Laws Income Tax
    Jurisdictional sanction for reassessment: invalid section 148 notice without the correct section 151 authority made revision unsustainable.
    April 2, 2026   Case Laws Income Tax
    Telescoping of surplus funds and capital gains computation reduced additions, while section 54 deduction failed for lack of proof.
    April 2, 2026   Case Laws Customs
    Reasonable belief and reverse burden in gold seizure upheld; belated retraction failed, and absolute confiscation was restored.
    April 2, 2026   Case Laws Customs
    Binding appellate order and deposit of duty barred further detention of confiscated goods, allowing release for re-export.
    April 2, 2026   Case Laws Customs
    Shipping bill amendments for MEIS benefit allowed where a wrong declaration was treated as a curable procedural lapse.
    April 2, 2026   Case Laws Customs
    Customs broker penalty and post-resolution tax claims fail where no proved contravention and resolution plan extinguishes dues
    April 2, 2026   Case Laws Customs
    Knowledge of contraband goods is essential before penalising a customs broker for factory-sealed export consignments.
    April 2, 2026   Case Laws IBC
    Finality of possession under insolvency proceedings bars reopening access claims, while third parties may seek independent relief.
    April 2, 2026   Case Laws IBC
    Written acknowledgment and co-extensive guarantor liability kept insolvency action within limitation despite "without prejudice" wording.
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April 2, 2026   Case Laws Income Tax
Underwriting commission to a non-resident was not fees for technical services because no technical knowledge was made available.
April 2, 2026   Case Laws Income Tax
Arm's length interest on inter-company loans cannot be raised solely for unsecured subsidiary lending where no fresh risk change is shown.
April 2, 2026   Case Laws Income Tax
Transfer pricing comparability challenge rejected where Revenue sought first-time exclusion of an accepted comparable before the Tribunal.
April 2, 2026   Case Laws Income Tax
Transfer pricing, TDS and revenue expense issues resolved by following earlier rulings in recurring group-company disputes.
April 2, 2026   Case Laws Income Tax
Contract expenditure allowed where unrebutted documentary evidence proved subcontract payments and supported the corresponding income claim.
April 2, 2026   Case Laws Income Tax
Liberal construction of sufficient cause justifies condonation of inordinate delay where criminal proceedings and jail confinement explained the default.
April 2, 2026   Case Laws Income Tax
Penalty under section 272A(1)(d) deleted after quantum proceedings were restored and the assessee's conduct was considered.
April 2, 2026   Case Laws Income Tax
Debatable provident fund adjustment cannot be made under prima facie processing when jurisdictional precedent favours the assessee.
April 2, 2026   Case Laws Income Tax
Public-domain data access and marketing support services failed royalty and make-available tests under the India-US DTAA.
April 2, 2026   Case Laws Income Tax
Taxability of buy-back interest depends on actual receipt and proof that premium or interest was income in the assessee's hands.
April 2, 2026   Case Laws Income Tax
Unexplained investment addition deleted where only third-party material existed and no corroborative evidence linked the assessee to on-money payment.
April 2, 2026   Case Laws Income Tax
Jurisdictional sanction for reassessment: invalid section 148 notice without the correct section 151 authority made revision unsustainable.
April 2, 2026   Case Laws Income Tax
Telescoping of surplus funds and capital gains computation reduced additions, while section 54 deduction failed for lack of proof.
April 2, 2026   Case Laws Customs
Reasonable belief and reverse burden in gold seizure upheld; belated retraction failed, and absolute confiscation was restored.
April 2, 2026   Case Laws Customs
Binding appellate order and deposit of duty barred further detention of confiscated goods, allowing release for re-export.
April 2, 2026   Case Laws Customs
Shipping bill amendments for MEIS benefit allowed where a wrong declaration was treated as a curable procedural lapse.
April 2, 2026   Case Laws Customs
Customs broker penalty and post-resolution tax claims fail where no proved contravention and resolution plan extinguishes dues
April 2, 2026   Case Laws Customs
Knowledge of contraband goods is essential before penalising a customs broker for factory-sealed export consignments.
April 2, 2026   Case Laws IBC
Finality of possession under insolvency proceedings bars reopening access claims, while third parties may seek independent relief.
April 2, 2026   Case Laws IBC
Written acknowledgment and co-extensive guarantor liability kept insolvency action within limitation despite "without prejudice" wording.

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Income Tax

Income taxable in India - Fixed place PE in India - project...

Indian Income Tax: Offshore Supply Profits Not Attributable to Project Office Lacking Permanent Establishment Status Under BTIL.

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Income Tax August 22, 2023 Case Laws AT
Income taxable in India - Fixed place PE in India - project office in India - none of the conditions of fixed place PE stand satisfied - the attribution of profit qua the receipts from offshore supplies to the alleged fixed place PE in the form of BTIL is unsustainable as, in our view, BTIL cannot be construed as PE of the assessee in India. - AT
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