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    June 2, 2026   Case LawsGST
    GST rate reduction profiteering on cinema tickets upheld, with price rollback breach, prospective interest, and no retrospective penalty.
    June 2, 2026   Case LawsIncome Tax
    DTAA protection for overseas employment per-diem: non-resident salary from UK assignment was held not taxable in India.
    June 2, 2026   Case LawsIncome Tax
    Transfer pricing consistency on ITES, receivables, and imported assets led to relief for the assessee.
    June 2, 2026   Case LawsIncome Tax
    Member-credit society deduction upheld for business income and related interest, while section 80P(2)(d) authorities were found irrelevant.
    June 2, 2026   Case LawsIncome Tax
    Rectification limitation and fertilizer subsidy character: reassessment order survives DTVSV settlement, and subsidy is capital receipt.
    June 2, 2026   Case LawsIncome Tax
    Business income treatment for mandatory fixed-deposit interest secured deduction eligibility for cold chain profits and deleted related additions.
    June 2, 2026   Case LawsIncome Tax
    Dominant purpose test preserves section 11 exemption where hall letting remains incidental to charitable education and welfare activities.
    June 2, 2026   Case LawsIncome Tax
    Agricultural land outside capital asset treatment leads ITAT to delete capital gains, section 50C, and alleged on-money additions.
    June 2, 2026   Case LawsIncome Tax
    Jurisdictional objection barred by delay, while unexplained cash addition survived for lack of supporting cash book entries.
    June 2, 2026   Case LawsIncome Tax
    Foreign salary in Sweden not taxable under Black Money Act or India-Sweden DTAA; additions deleted by ITAT.
    June 2, 2026   Case LawsIncome Tax
    Foreign asset source of funds dispute remanded for fresh evidence on residential status and investment trail.
    June 2, 2026   Case LawsIncome Tax
    Black Money Act limitation turns on notice service; pre-notice foreign information exchange time cannot be excluded from assessment period.
    June 2, 2026   Case LawsCustoms
    Reversal of CENVAT credit before notice preserves higher duty drawback entitlement for exported netted garments.
    June 2, 2026   Case LawsCustoms
    Re-export of seized imported goods allowed subject to bond and bank guarantee, without examining seizure allegations.
    June 2, 2026   Case LawsIBC
    Material adverse effect and continuing default justified loan recall, Section 7 admission, and fresh limitation from arbitral award.
    June 2, 2026   Case LawsIBC
    Misrepresentation of foundational facts vitiates personal guarantor insolvency proceedings under the IBC, with liberty to refile.
    June 2, 2026   Case LawsIBC
    Unregistered profit-sharing agreements cannot justify occupation of corporate debtor premises during CIRP; repossession by the Resolution Professional...
    June 2, 2026   Case LawsIBC
    Res judicata bars reopening of claims after resolution plan approval, and unconditional plan implementation must proceed without added contingencies.
    June 2, 2026   Case LawsIBC
    Bona fide participation in e-auction and value maximization justified setting aside exclusion and ordering a fresh auction.
    June 2, 2026   Case LawsIBC
    E-filing limitation under IBC counts from the filing date itself, even after office hours, and delay was condoned.
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    June 2, 2026   Case Laws GST
    GST rate reduction profiteering on cinema tickets upheld, with price rollback breach, prospective interest, and no retrospective penalty.
    June 2, 2026   Case Laws Income Tax
    DTAA protection for overseas employment per-diem: non-resident salary from UK assignment was held not taxable in India.
    June 2, 2026   Case Laws Income Tax
    Transfer pricing consistency on ITES, receivables, and imported assets led to relief for the assessee.
    June 2, 2026   Case Laws Income Tax
    Member-credit society deduction upheld for business income and related interest, while section 80P(2)(d) authorities were found irrelevant.
    June 2, 2026   Case Laws Income Tax
    Rectification limitation and fertilizer subsidy character: reassessment order survives DTVSV settlement, and subsidy is capital receipt.
    June 2, 2026   Case Laws Income Tax
    Business income treatment for mandatory fixed-deposit interest secured deduction eligibility for cold chain profits and deleted related additions.
    June 2, 2026   Case Laws Income Tax
    Dominant purpose test preserves section 11 exemption where hall letting remains incidental to charitable education and welfare activities.
    June 2, 2026   Case Laws Income Tax
    Agricultural land outside capital asset treatment leads ITAT to delete capital gains, section 50C, and alleged on-money additions.
    June 2, 2026   Case Laws Income Tax
    Jurisdictional objection barred by delay, while unexplained cash addition survived for lack of supporting cash book entries.
    June 2, 2026   Case Laws Income Tax
    Foreign salary in Sweden not taxable under Black Money Act or India-Sweden DTAA; additions deleted by ITAT.
    June 2, 2026   Case Laws Income Tax
    Foreign asset source of funds dispute remanded for fresh evidence on residential status and investment trail.
    June 2, 2026   Case Laws Income Tax
    Black Money Act limitation turns on notice service; pre-notice foreign information exchange time cannot be excluded from assessment period.
    June 2, 2026   Case Laws Customs
    Reversal of CENVAT credit before notice preserves higher duty drawback entitlement for exported netted garments.
    June 2, 2026   Case Laws Customs
    Re-export of seized imported goods allowed subject to bond and bank guarantee, without examining seizure allegations.
    June 2, 2026   Case Laws IBC
    Material adverse effect and continuing default justified loan recall, Section 7 admission, and fresh limitation from arbitral award.
    June 2, 2026   Case Laws IBC
    Misrepresentation of foundational facts vitiates personal guarantor insolvency proceedings under the IBC, with liberty to refile.
    June 2, 2026   Case Laws IBC
    Unregistered profit-sharing agreements cannot justify occupation of corporate debtor premises during CIRP; repossession by the Resolution Professional upheld.
    June 2, 2026   Case Laws IBC
    Res judicata bars reopening of claims after resolution plan approval, and unconditional plan implementation must proceed without added contingencies.
    June 2, 2026   Case Laws IBC
    Bona fide participation in e-auction and value maximization justified setting aside exclusion and ordering a fresh auction.
    June 2, 2026   Case Laws IBC
    E-filing limitation under IBC counts from the filing date itself, even after office hours, and delay was condoned.

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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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