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    October 5, 2026   Case Laws GST
    Electronic Cash Ledger Credits Do Not End Delayed GST Interest Until Debited Against Return Liability
    October 5, 2026   Case Laws GST
    Recurring-issue exception to GST appeal thresholds requires genuine wider implications; absent proof, the departmental appeal is not maintainable.
    October 5, 2026   Case Laws Income Tax
    Judicial discipline requires consistent reassessment treatment where identical facts were decided for the same taxpayer in the preceding assessment ye...
    October 5, 2026   Case Laws Income Tax
    Limitation for Section 153C notices is measured from the assessment year in which satisfaction is recorded, excluding stale assessment years.
    October 5, 2026   Case Laws Income Tax
    Section 153C limitation invalidates a notice where the relevant assessment year falls outside the statutory look-back period.
    October 5, 2026   Case Laws Income Tax
    Revised Form-3 payment deadlines cannot require impossible compliance, preserving settlement closure after prompt payment under Vivad se Vishwas.
    October 5, 2026   Case Laws Income Tax
    Extended-period reassessment and digital evidence require statutory nexus and independent corroboration before tax additions can stand.
    October 5, 2026   Case Laws Income Tax
    TNMM aggregation of royalty with manufacturing precludes separate benchmarking, while non-comparable diversified service providers require exclusion.
    October 5, 2026   Case Laws Income Tax
    Penalty for inaccurate particulars requires more than a Section 43B addition or a disclosed foreign-dividend reporting mismatch.
    October 5, 2026   Case Laws Income Tax
    Net profit estimation in vegetable commission business requires expense analysis, leading to recomputation of taxable business income.
    October 5, 2026   Case Laws Income Tax
    Recording satisfaction in assessment proceedings is essential before cash-receipt penalties can be initiated; absent satisfaction, penalty fails.
    October 5, 2026   Case Laws Income Tax
    Search-related reassessment procedure displaces ordinary scrutiny assessment and invalidates regular assessments made after a search operation.
    October 5, 2026   Case Laws Income Tax
    Section 50C excludes unregistered contractual rights to seek land conveyance, preventing deemed-value recomputation of long-term capital gains.
    October 5, 2026   Case Laws Income Tax
    Family Jewellery Source Explanation: Valuation reports and family ownership evidence supported deletion of the unexplained-income addition.
    October 5, 2026   Case Laws Income Tax
    Accommodation loan reassessment may stand while additions fail where loans are repaid through banking channels and records establish repayment.
    October 5, 2026   Case Laws Income Tax
    Foreign Salary Taxability: Passport, employment and NRE account evidence support non-resident claims despite absent foreign tax documents.
    October 5, 2026   Case Laws Income Tax
    Genuine BSE futures and options profits cannot be treated as unexplained cash credit without evidence of tainted counterparties.
    October 5, 2026   Case Laws Income Tax
    Specific penalty charges in notices are mandatory, while disputed salary disallowances may be limited after factual assessment.
    October 5, 2026   Case Laws Income Tax
    Faceless Penalty Scheme jurisdiction shifts to the Penalty Unit once operational, invalidating Assessment Unit cash-contribution penalties.
    October 5, 2026   Case Laws Income Tax
    Agreement-date stamp valuation requires the same registered property, fixed consideration, and qualifying payment; an unrelated prior booking cannot a...
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October 5, 2026   Case Laws GST
Electronic Cash Ledger Credits Do Not End Delayed GST Interest Until Debited Against Return Liability
October 5, 2026   Case Laws GST
Recurring-issue exception to GST appeal thresholds requires genuine wider implications; absent proof, the departmental appeal is not maintainable.
October 5, 2026   Case Laws Income Tax
Judicial discipline requires consistent reassessment treatment where identical facts were decided for the same taxpayer in the preceding assessment year.
October 5, 2026   Case Laws Income Tax
Limitation for Section 153C notices is measured from the assessment year in which satisfaction is recorded, excluding stale assessment years.
October 5, 2026   Case Laws Income Tax
Section 153C limitation invalidates a notice where the relevant assessment year falls outside the statutory look-back period.
October 5, 2026   Case Laws Income Tax
Revised Form-3 payment deadlines cannot require impossible compliance, preserving settlement closure after prompt payment under Vivad se Vishwas.
October 5, 2026   Case Laws Income Tax
Extended-period reassessment and digital evidence require statutory nexus and independent corroboration before tax additions can stand.
October 5, 2026   Case Laws Income Tax
TNMM aggregation of royalty with manufacturing precludes separate benchmarking, while non-comparable diversified service providers require exclusion.
October 5, 2026   Case Laws Income Tax
Penalty for inaccurate particulars requires more than a Section 43B addition or a disclosed foreign-dividend reporting mismatch.
October 5, 2026   Case Laws Income Tax
Net profit estimation in vegetable commission business requires expense analysis, leading to recomputation of taxable business income.
October 5, 2026   Case Laws Income Tax
Recording satisfaction in assessment proceedings is essential before cash-receipt penalties can be initiated; absent satisfaction, penalty fails.
October 5, 2026   Case Laws Income Tax
Search-related reassessment procedure displaces ordinary scrutiny assessment and invalidates regular assessments made after a search operation.
October 5, 2026   Case Laws Income Tax
Section 50C excludes unregistered contractual rights to seek land conveyance, preventing deemed-value recomputation of long-term capital gains.
October 5, 2026   Case Laws Income Tax
Family Jewellery Source Explanation: Valuation reports and family ownership evidence supported deletion of the unexplained-income addition.
October 5, 2026   Case Laws Income Tax
Accommodation loan reassessment may stand while additions fail where loans are repaid through banking channels and records establish repayment.
October 5, 2026   Case Laws Income Tax
Foreign Salary Taxability: Passport, employment and NRE account evidence support non-resident claims despite absent foreign tax documents.
October 5, 2026   Case Laws Income Tax
Genuine BSE futures and options profits cannot be treated as unexplained cash credit without evidence of tainted counterparties.
October 5, 2026   Case Laws Income Tax
Specific penalty charges in notices are mandatory, while disputed salary disallowances may be limited after factual assessment.
October 5, 2026   Case Laws Income Tax
Faceless Penalty Scheme jurisdiction shifts to the Penalty Unit once operational, invalidating Assessment Unit cash-contribution penalties.
October 5, 2026   Case Laws Income Tax
Agreement-date stamp valuation requires the same registered property, fixed consideration, and qualifying payment; an unrelated prior booking cannot apply.

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

Income deemed to accrue or arise in India - fees for technical...

Technical Service Fees Taxable Under India-Singapore DTAA Article 12 for Deliverables to RCITP.

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Income Tax August 28, 2023 Case Laws AT
Income deemed to accrue or arise in India - fees for technical services - the assessee is making available RCITP all reports, analysis, tests, tables, plans, drawings or other documents in any form including electronic or printed form for the use of RCITP which enables RCITP to apply and use all these deliverables for its business purposes - Taxable u/A 12 of India-Singapore DTAA - AT
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