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    June 9, 2026   Case LawsIncome Tax
    Foreign asset disclosure in a substituted return can defeat penalty for an earlier omission when assessment accepts it.
    June 9, 2026   Case LawsIncome Tax
    Comparability filters in TNMM require upfront R&D screening and broadly similar turnover scales for software services.
    June 9, 2026   Case LawsIncome Tax
    Functional comparability in wholesale auto-component trading excludes retail and after-sales comparables, deleting transfer pricing adjustments
    June 9, 2026   Case LawsIncome Tax
    Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
    June 9, 2026   Case LawsIncome Tax
    Pass-through LLC self-dealing defeats transfer pricing adjustment; linked receivables and profit recomputation were also deleted.
    June 9, 2026   Case LawsIncome Tax
    Transfer pricing comparability: predominantly manufacturing comparables were excluded, and IT support charges were not fixed at nil.
    June 9, 2026   Case LawsIncome Tax
    Substantial compliance in transfer pricing documentation defeats penalty for diamond trade record shortfall where arm's length pricing stood accepted
    June 9, 2026   Case LawsIncome Tax
    Double taxation through rectification was impermissible where income already shown under proper heads was added again to business income.
    June 9, 2026   Case LawsIncome Tax
    Bona fide return error defeats misreporting penalty where no specific statutory clause is identified in assessment.
    June 9, 2026   Case LawsIncome Tax
    Interest computation in return processing restored for fresh factual verification and de novo adjudication.
    June 9, 2026   Case LawsIncome Tax
    Revisional power under section 264 cannot worsen assessee's position; cash deposits explained from past salary savings.
    June 9, 2026   Case LawsIncome Tax
    Fair market value of surrendered tenancy rights can determine cost of acquisition for redeveloped property gains
    June 9, 2026   Case LawsCustoms
    Customs valuation enhancement fails when based on a retracted statement and non-comparable contemporaneous import invoices.
    June 9, 2026   Case LawsService Tax
    Transportation charges and foreign-branch services were held outside service tax, while disclosed records defeated extended limitation.
    June 9, 2026   Case LawsService Tax
    Negative list treatment for food grain transport without consignment notes defeats service tax and extended limitation demand.
    June 9, 2026   Case LawsIndian Laws
    Arbitration clause confined to work-execution disputes; tax reimbursement claim under separate taxes clause was non-arbitrable on referral review.
    June 8, 2026   NotificationsMoney Laundering
    Financial intelligence sharing expanded to include the Directorate of Naval Intelligence under the PMLA notification.
    June 8, 2026   NotificationsCustoms
    Common adjudicating authority appointed for specified customs show cause notices against an importer
    June 8, 2026   NotificationsFEMA
    Export proceeds realisation period cut from fifteen months to nine months under amended FEMA export regulations.
    June 8, 2026   CircularsIBC
    Standard claim, consent and proxy formats prescribed for personal guarantor insolvency resolution processes.
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    June 9, 2026   Case Laws Income Tax
    Foreign asset disclosure in a substituted return can defeat penalty for an earlier omission when assessment accepts it.
    June 9, 2026   Case Laws Income Tax
    Comparability filters in TNMM require upfront R&D screening and broadly similar turnover scales for software services.
    June 9, 2026   Case Laws Income Tax
    Functional comparability in wholesale auto-component trading excludes retail and after-sales comparables, deleting transfer pricing adjustments
    June 9, 2026   Case Laws Income Tax
    Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim remanded.
    June 9, 2026   Case Laws Income Tax
    Pass-through LLC self-dealing defeats transfer pricing adjustment; linked receivables and profit recomputation were also deleted.
    June 9, 2026   Case Laws Income Tax
    Transfer pricing comparability: predominantly manufacturing comparables were excluded, and IT support charges were not fixed at nil.
    June 9, 2026   Case Laws Income Tax
    Substantial compliance in transfer pricing documentation defeats penalty for diamond trade record shortfall where arm's length pricing stood accepted
    June 9, 2026   Case Laws Income Tax
    Double taxation through rectification was impermissible where income already shown under proper heads was added again to business income.
    June 9, 2026   Case Laws Income Tax
    Bona fide return error defeats misreporting penalty where no specific statutory clause is identified in assessment.
    June 9, 2026   Case Laws Income Tax
    Interest computation in return processing restored for fresh factual verification and de novo adjudication.
    June 9, 2026   Case Laws Income Tax
    Revisional power under section 264 cannot worsen assessee's position; cash deposits explained from past salary savings.
    June 9, 2026   Case Laws Income Tax
    Fair market value of surrendered tenancy rights can determine cost of acquisition for redeveloped property gains
    June 9, 2026   Case Laws Customs
    Customs valuation enhancement fails when based on a retracted statement and non-comparable contemporaneous import invoices.
    June 9, 2026   Case Laws Service Tax
    Transportation charges and foreign-branch services were held outside service tax, while disclosed records defeated extended limitation.
    June 9, 2026   Case Laws Service Tax
    Negative list treatment for food grain transport without consignment notes defeats service tax and extended limitation demand.
    June 9, 2026   Case Laws Indian Laws
    Arbitration clause confined to work-execution disputes; tax reimbursement claim under separate taxes clause was non-arbitrable on referral review.
    June 8, 2026   Notifications Money Laundering
    Financial intelligence sharing expanded to include the Directorate of Naval Intelligence under the PMLA notification.
    June 8, 2026   Notifications Customs
    Common adjudicating authority appointed for specified customs show cause notices against an importer
    June 8, 2026   Notifications FEMA
    Export proceeds realisation period cut from fifteen months to nine months under amended FEMA export regulations.
    June 8, 2026   Circulars IBC
    Standard claim, consent and proxy formats prescribed for personal guarantor insolvency resolution processes.

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

      Denial of Foreign tax credit - If the finding of lower authority...

      Foreign Tax Credit Granted: Offshore Transaction Income with US Source Not Taxable Under Effective Management Rule.

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      Income TaxSeptember 2, 2023Case LawsAT
      Denial of Foreign tax credit - If the finding of lower authority regarding place of effective management is presumed to be correct, in that case, no tax could be charged as the transaction took place off shores and income was generated in USA - Benefit of FTC allowed - AT
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