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    September 30, 2026   Case Laws Income Tax
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    September 30, 2026   Case Laws Income Tax
    Agreement-date stamp duty valuation governs stock-in-trade sales when non-cash consideration is received before the sale agreement.
    September 30, 2026   Case Laws Income Tax
    Unaccounted quarry sales: only reasonably estimated profit is taxable, while cash sales already disclosed cannot be taxed twice.
    September 30, 2026   Case Laws Income Tax
    Reassessment limitation excludes section 148A response time; Indian support-services affiliate does not create a dependent agent PE.
    September 30, 2026   Case Laws Income Tax
    Dependent-agent permanent establishment requires proof of actual contractual authority; liaison and support functions alone do not suffice.
    September 30, 2026   Case Laws Income Tax
    Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
    September 30, 2026   Case Laws Income Tax
    Goodwill in a slump sale qualifies for depreciation when the transferred business includes its operating intangible assets.
    September 30, 2026   Case Laws Income Tax
    Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
    September 30, 2026   Case Laws Income Tax
    Extinguishment of specific-performance rights permits capital-gains deduction when payment clears title and enables property transfer.
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    Excess baggage jewellery detention permits return application and consensual minor penalty for admitted Customs Baggage Rules infraction.
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    September 30, 2026   Case Laws Customs
    Statutory notice period for seized goods requires release when notice is absent; provisional release cannot preserve detention.
    September 30, 2026   Case Laws Customs
    Customs adjudication evidence rules bar uncross-examined Section 108 statements and uncertified electronic records, defeating unsupported abetment pen...
    September 30, 2026   Case Laws Customs
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    September 30, 2026   Case Laws Companies Law
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September 30, 2026   Case Laws Income Tax
DRP direction compliance permits rectification of obvious omissions, while PE, reimbursement, and guarantee pricing require factual examination.
September 30, 2026   Case Laws IBC
Committee of creditors' commercial wisdom permits replacement of a resolution professional, while fees remain subject to adjudication.
September 30, 2026   Case Laws Income Tax
Charitable registration scrutiny is confined to genuine activities, while domestic overseas-study scholarships remain within educational objects.
September 30, 2026   Case Laws Income Tax
Unexplained election expenditure requires corroborated seized-document entries and correct assessment-year attribution for tax assessment purposes.
September 30, 2026   Case Laws Income Tax
Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements remained untaxed.
September 30, 2026   Case Laws Income Tax
Agreement-date stamp duty valuation governs stock-in-trade sales when non-cash consideration is received before the sale agreement.
September 30, 2026   Case Laws Income Tax
Unaccounted quarry sales: only reasonably estimated profit is taxable, while cash sales already disclosed cannot be taxed twice.
September 30, 2026   Case Laws Income Tax
Reassessment limitation excludes section 148A response time; Indian support-services affiliate does not create a dependent agent PE.
September 30, 2026   Case Laws Income Tax
Dependent-agent permanent establishment requires proof of actual contractual authority; liaison and support functions alone do not suffice.
September 30, 2026   Case Laws Income Tax
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pricing.
September 30, 2026   Case Laws Income Tax
Goodwill in a slump sale qualifies for depreciation when the transferred business includes its operating intangible assets.
September 30, 2026   Case Laws Income Tax
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA.
September 30, 2026   Case Laws Income Tax
Extinguishment of specific-performance rights permits capital-gains deduction when payment clears title and enables property transfer.
September 30, 2026   Case Laws Customs
Excess baggage jewellery detention permits return application and consensual minor penalty for admitted Customs Baggage Rules infraction.
September 30, 2026   Case Laws Customs
Duty drawback survives RBI-backed rupee export remittances and completed exports despite alleged diversion to intermediary ports.
September 30, 2026   Case Laws Customs
Statutory notice period for seized goods requires release when notice is absent; provisional release cannot preserve detention.
September 30, 2026   Case Laws Customs
Customs adjudication evidence rules bar uncross-examined Section 108 statements and uncertified electronic records, defeating unsupported abetment penalties.
September 30, 2026   Case Laws Customs
Customs broker abetment requires proof of knowledge, collusion or active assistance, not merely alleged IEC verification failure.
September 30, 2026   Case Laws Customs
Formulated astaxanthin preparations qualify as food preparations where nutritional function predominates and colour remains incidental to dietary use.
September 30, 2026   Case Laws Companies Law
Consent terms in oppression proceedings bind parties and can resolve appellate challenges without merits adjudication, quashing contested findings.

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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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