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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...
    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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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

TP Adjustment - Addition as ‘Fees for Technical Services’ ign...

Transfer Pricing Dispute Over Technical Services Fee Sent Back for Re-evaluation; Assessee Claims It's a Reimbursement.

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Income Tax September 16, 2023 Case Laws AT
TP Adjustment - Addition as ‘Fees for Technical Services’ ignoring the assessee’s contention that it was purely reimbursement received for Construction and Management Expenses - Matter restored back for fresh adjudication - AT
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