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    June 9, 2026   Case Laws Income Tax
    Article 8 shipping receipts from feeder vessels and slot hire held covered by the DTAA, not separately taxed.
    June 9, 2026   Case Laws Income Tax
    Arrears of superannuation fund perquisites qualify for salary relief, and Rule 21A applies to the claim.
    June 9, 2026   Case Laws Income Tax
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    June 9, 2026   Case Laws Income Tax
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    June 9, 2026   Case Laws Income Tax
    Transfer pricing adjustments remanded for fresh review of intra-group services, sensor assembling method and comparables analysis
    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.
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June 9, 2026   Case Laws Income Tax
Article 8 shipping receipts from feeder vessels and slot hire held covered by the DTAA, not separately taxed.
June 9, 2026   Case Laws Income Tax
Arrears of superannuation fund perquisites qualify for salary relief, and Rule 21A applies to the claim.
June 9, 2026   Case Laws Income Tax
Burden of proof in penalty cases defeats cash-loan penalties based only on third-party seized papers
June 9, 2026   Case Laws Income Tax
Royalty and management support service adjustments fail where costs were recovered and aggregated TNMM benchmarking applied.
June 9, 2026   Case Laws Income Tax
Transfer pricing adjustments remanded for fresh review of intra-group services, sensor assembling method and comparables analysis
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.

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

TP Adjustments - AO does not have the jurisdiction to propose...

Assessing Officer Can't Adjust Transfer Pricing Without TPO Reference; Adjustments Deemed Invalid and Deleted.

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Income Tax November 30, 2023 Case Laws AT
TP Adjustments - AO does not have the jurisdiction to propose any transfer pricing adjustment in case where he has not made any reference to the TPO. Therefore the additional made by the assessing officer towards transfer pricing adjustment is not tenable and is deleted. - AT
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