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    August 29, 2026   Case Laws Income Tax
    Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
    August 29, 2026   Case Laws Income Tax
    TDS-default expenditure requires proof of prior-year disallowance; unnotified entities cannot claim exemption despite pending writ proceedings.
    August 29, 2026   Case Laws Income Tax
    Double addition of goodwill cannot stand where its book write-off was already added back; depreciation disallowance remained.
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August 29, 2026   Case Laws Income Tax
Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and margin issues.
August 29, 2026   Case Laws Income Tax
TDS-default expenditure requires proof of prior-year disallowance; unnotified entities cannot claim exemption despite pending writ proceedings.
August 29, 2026   Case Laws Income Tax
Double addition of goodwill cannot stand where its book write-off was already added back; depreciation disallowance remained.
August 29, 2026   Case Laws Income Tax
Search-related assessment framework governs post-search proceedings, while evidentiary burdens shape loan, cash, and transfer-pricing adjustments.
August 29, 2026   Case Laws Income Tax
Trade discount characterisation prevails over tax statement labels when invoice reconciliation establishes the receipts' true nature.
August 29, 2026   Case Laws Income Tax
Interest on enhanced compensation remains taxable, while the statutory half deduction must reduce taxable income.
August 29, 2026   Case Laws Customs
Reasonable Time for Drawback Recovery invalidates delayed recovery and bank-account attachment where fraud or suppression is not alleged.
August 29, 2026   Case Laws Customs
Customs reclassification requires technical evidence; unsupported rejection of mixed-fibre fabric classification cannot sustain duty, interest or penalties.
August 29, 2026   Case Laws Companies Law
Territorial jurisdiction under Article 226(2) requires substantial nexus and forum convenience, directing the investigation challenge to Mumbai.
August 29, 2026   Case Laws IBC
Resolution-plan tax waivers do not cover GST liabilities arising after the plan's specified cut-off, requiring statutory appeal and pre-deposit.
August 29, 2026   Case Laws Money Laundering
PMLA provisional attachment challenges must ordinarily follow statutory remedies where no jurisdictional or natural justice exception is established.
August 29, 2026   Case Laws Money Laundering
Bank account freezing requires statutory authority; anti-money-laundering compliance and KYC monitoring do not permit unilateral indefinite restrictions.
August 29, 2026   Case Laws Service Tax
Best-judgment service tax assessments require verified records, while limitation and duplicate recovery constraints govern reassessment.
August 29, 2026   Case Laws Service Tax
Wet leasing of compressor equipment remains taxable as supply of tangible goods service where control stays with the owner.
August 29, 2026   Case Laws Central Excise
CENVAT credit on contractor-procured capital goods remains available when factory receipt supports captive manufacturing installation.
August 28, 2026   Notifications Customs
Customs tariff valuation for edible oils, brass scrap, areca nuts, gold and silver continues under substituted valuation tables.
August 28, 2026   Circulars DGFT
Pre-shipment inspection certificates must be issued on inspection date, with automated inspector verification and expanded digital evidence uploads.
August 28, 2026   Case Laws GST
Regular bail in alleged fake-invoice input tax credit prosecution follows custody, documentary evidence, and low interference risk.
August 28, 2026   Case Laws GST
Ex parte GST adjudication may be reopened to restore a taxpayer's opportunity to reply, submit evidence, and be heard.
August 28, 2026   Case Laws GST
Composite GST assessment orders for distinct tax periods require separate notices and hearings before any fresh proceedings.

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Home › Highlights › Income Tax › 2024 › January, 2024 › This
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Income Tax

Reopening of assessment u/s 147 - Time limit for notice - (TOLA)...

Reassessment Invalid: Notice Issued in June 2021 Exceeds Limitation Period, Rendering Proceedings Time-Barred.

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Income Tax January 18, 2024 Case Laws HC
Reopening of assessment u/s 147 - Time limit for notice - (TOLA) application - as the foundation of the entire reassessment proceeding, viz., the notice issued in June 2021 itself was barred by limitation in view of non-applicability of Notification No. 20/2021, the superstructure sitting thereon, viz., the reassessment proceedings initiated pursuant to judgment in Ashish Agarwal will also be regarded as beyond time limit. - HC
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Acts Income Tax
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