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    July 3, 2026   Case LawsIncome Tax
    DCF valuation of unquoted shares cannot be replaced by NAV, though the Assessing Officer may scrutinise defects.
    July 3, 2026   Case LawsIncome Tax
    Banking tax issues: actuarial employee-benefit provisions, NPA interest, securities valuation and MAT non-applicability to new banks
    July 3, 2026   Case LawsIncome Tax
    PILCOM managing committee status defeated protective tax additions on World Cup receipts and foreign match income.
    July 3, 2026   Case LawsIncome Tax
    Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
    July 3, 2026   Case LawsCustoms
    Burden of proof for notified gold shifts on recovery from controlled premises; penalty sustained but reduced on quantum.
    July 3, 2026   Case LawsCustoms
    Reasonable belief for seizure of gold under customs law must be based on objective material, not suspicion alone.
    July 3, 2026   Case LawsCustoms
    Imported nickel-chromium wire classification: prior co-ordinate bench ruling barred reclassification absent factual change or legal change.
    July 3, 2026   Case LawsCustoms
    Contemporaneous protest and deliberate misdeclaration: re-measurement rejected, but customs penalty set aside for marginal slab overage.
    July 3, 2026   Case LawsCustoms
    EPS-ECU parts classified as steering system components where no independent electrical function exists.
    July 3, 2026   Case LawsCustoms
    Fully mechanised jewellery exports satisfy Replenishment Scheme value addition; customs duty demand and penalties were set aside.
    July 3, 2026   Case LawsCustoms
    Related-party customs valuation: declared prices rejected, deductive and computed methods applied, with SAD exemption denied
    July 3, 2026   Case LawsIBC
    Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
    July 3, 2026   Case LawsIBC
    Bankruptcy filing timeline under Section 121(2) is directory; delay may be condoned on sufficient cause.
    July 3, 2026   Case LawsIBC
    Claim verification in insolvency: unsupported farmer compensation failed, and lease charges were limited to the insolvency commencement date.
    July 3, 2026   Case LawsIBC
    Valid service through registered email sustains Section 7 admission for interest default and revived loan dues.
    July 3, 2026   Case LawsIBC
    Registered homebuyer claims in CIRP records survive delay when notice is absent and allotment details are documented.
    July 3, 2026   Case LawsMoney Laundering
    Inter-agency sharing under PMLA upheld where prima facie extremist-funding material justified continued investigation at early stage.
    July 3, 2026   Case LawsMoney Laundering
    Continuing money-laundering doctrine sustains provisional attachment where proceeds of crime are dealt with after predicate offence.
    July 3, 2026   Case LawsService Tax
    Overseas services consumed abroad were outside reverse charge tax, and the demand failed on classification and limitation.
    July 3, 2026   Case LawsService Tax
    SEZ refund limitation cannot override the SEZ exemption scheme; time-bar rejection of service tax refund was set aside.
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    July 3, 2026   Case Laws Income Tax
    DCF valuation of unquoted shares cannot be replaced by NAV, though the Assessing Officer may scrutinise defects.
    July 3, 2026   Case Laws Income Tax
    Banking tax issues: actuarial employee-benefit provisions, NPA interest, securities valuation and MAT non-applicability to new banks
    July 3, 2026   Case Laws Income Tax
    PILCOM managing committee status defeated protective tax additions on World Cup receipts and foreign match income.
    July 3, 2026   Case Laws Income Tax
    Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed.
    July 3, 2026   Case Laws Customs
    Burden of proof for notified gold shifts on recovery from controlled premises; penalty sustained but reduced on quantum.
    July 3, 2026   Case Laws Customs
    Reasonable belief for seizure of gold under customs law must be based on objective material, not suspicion alone.
    July 3, 2026   Case Laws Customs
    Imported nickel-chromium wire classification: prior co-ordinate bench ruling barred reclassification absent factual change or legal change.
    July 3, 2026   Case Laws Customs
    Contemporaneous protest and deliberate misdeclaration: re-measurement rejected, but customs penalty set aside for marginal slab overage.
    July 3, 2026   Case Laws Customs
    EPS-ECU parts classified as steering system components where no independent electrical function exists.
    July 3, 2026   Case Laws Customs
    Fully mechanised jewellery exports satisfy Replenishment Scheme value addition; customs duty demand and penalties were set aside.
    July 3, 2026   Case Laws Customs
    Related-party customs valuation: declared prices rejected, deductive and computed methods applied, with SAD exemption denied
    July 3, 2026   Case Laws IBC
    Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law.
    July 3, 2026   Case Laws IBC
    Bankruptcy filing timeline under Section 121(2) is directory; delay may be condoned on sufficient cause.
    July 3, 2026   Case Laws IBC
    Claim verification in insolvency: unsupported farmer compensation failed, and lease charges were limited to the insolvency commencement date.
    July 3, 2026   Case Laws IBC
    Valid service through registered email sustains Section 7 admission for interest default and revived loan dues.
    July 3, 2026   Case Laws IBC
    Registered homebuyer claims in CIRP records survive delay when notice is absent and allotment details are documented.
    July 3, 2026   Case Laws Money Laundering
    Inter-agency sharing under PMLA upheld where prima facie extremist-funding material justified continued investigation at early stage.
    July 3, 2026   Case Laws Money Laundering
    Continuing money-laundering doctrine sustains provisional attachment where proceeds of crime are dealt with after predicate offence.
    July 3, 2026   Case Laws Service Tax
    Overseas services consumed abroad were outside reverse charge tax, and the demand failed on classification and limitation.
    July 3, 2026   Case Laws Service Tax
    SEZ refund limitation cannot override the SEZ exemption scheme; time-bar rejection of service tax refund was set aside.

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      Home› Highlights › Income Tax › 2023 › August, 2023 › This
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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 TaxAugust 22, 2023Case LawsAT
      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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