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    July 14, 2026   Case LawsIncome Tax
    Sufficient cause and merits-based adjudication guide condonation of delayed appeals challenging section 143(1) processing and exemption denial.
    July 14, 2026   Case LawsIncome Tax
    Full and true disclosure governs settlement applications; income cannot be recharacterised under Sections 69B and 115BBE in settlement proceedings
    July 14, 2026   Case LawsIncome Tax
    Mandatory DRP directions must shape the final assessment; a post-limitation corrigendum cannot cure the statutory defect.
    July 14, 2026   Case LawsIncome Tax
    Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
    July 14, 2026   Case LawsIncome Tax
    Adequate enquiry limits section 263 revision; shareholder funding and commercially expedient purchases may avoid tax adjustments
    July 14, 2026   Case LawsIncome Tax
    Pecuniary jurisdiction for scrutiny notices is mandatory; notice by the wrong officer can invalidate the resulting assessment.
    July 14, 2026   Case LawsIncome Tax
    Open-access medical and educational activities outweigh an isolated religious object clause, supporting charitable registration and donation approval
    July 14, 2026   Case LawsIncome Tax
    Non-recourse receivables assignment is a sale, not borrowing; alleged discounting charges are not interest for TDS purposes.
    July 14, 2026   Case LawsIncome Tax
    Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
    July 14, 2026   Case LawsIncome Tax
    Turnover filters and receivables benchmarking reshape software-services transfer pricing: high-turnover comparables excluded and interest recomputed a...
    July 14, 2026   Case LawsIncome Tax
    Consistent depreciation treatment supports computer peripherals, film software libraries and demerged non-compete fees; production costs remain revenu...
    July 14, 2026   Case LawsIncome Tax
    Charitable medical relief survives hospital scale, surplus and premium facilities; retrospective registration cancellation and consequential donation ...
    July 14, 2026   Case LawsIncome Tax
    Medical relief remains charitable despite premium hospital operations; statutory enquiry focuses on genuine activities and application of income.
    July 14, 2026   Case LawsIncome Tax
    Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
    July 14, 2026   Case LawsIncome Tax
    Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
    July 14, 2026   Case LawsIncome Tax
    Lease deed stamp duty is revenue expenditure when it secures business use, preventing later capitalisation, amortisation, or depreciation claims.
    July 14, 2026   Case LawsIncome Tax
    Combined TNMM benchmarking bars separate royalty and GAM adjustments when those costs are embedded in the tested segment's operating base
    July 14, 2026   Case LawsIncome Tax
    Reasonable cause limits transfer-pricing penalties, while appellate enhancement cannot extend proceedings to transactions never included in initiation
    July 14, 2026   Case LawsCustoms
    Statutory admission screening limits respondent intervention, deferring maintainability and jurisdiction objections to the post-admission hearing.
    July 14, 2026   Case LawsSEBI
    Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
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    July 14, 2026   Case Laws Income Tax
    Sufficient cause and merits-based adjudication guide condonation of delayed appeals challenging section 143(1) processing and exemption denial.
    July 14, 2026   Case Laws Income Tax
    Full and true disclosure governs settlement applications; income cannot be recharacterised under Sections 69B and 115BBE in settlement proceedings
    July 14, 2026   Case Laws Income Tax
    Mandatory DRP directions must shape the final assessment; a post-limitation corrigendum cannot cure the statutory defect.
    July 14, 2026   Case Laws Income Tax
    Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration defer taxation.
    July 14, 2026   Case Laws Income Tax
    Adequate enquiry limits section 263 revision; shareholder funding and commercially expedient purchases may avoid tax adjustments
    July 14, 2026   Case Laws Income Tax
    Pecuniary jurisdiction for scrutiny notices is mandatory; notice by the wrong officer can invalidate the resulting assessment.
    July 14, 2026   Case Laws Income Tax
    Open-access medical and educational activities outweigh an isolated religious object clause, supporting charitable registration and donation approval
    July 14, 2026   Case Laws Income Tax
    Non-recourse receivables assignment is a sale, not borrowing; alleged discounting charges are not interest for TDS purposes.
    July 14, 2026   Case Laws Income Tax
    Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains computation
    July 14, 2026   Case Laws Income Tax
    Turnover filters and receivables benchmarking reshape software-services transfer pricing: high-turnover comparables excluded and interest recomputed at LIBOR plus 2%
    July 14, 2026   Case Laws Income Tax
    Consistent depreciation treatment supports computer peripherals, film software libraries and demerged non-compete fees; production costs remain revenue expenditure.
    July 14, 2026   Case Laws Income Tax
    Charitable medical relief survives hospital scale, surplus and premium facilities; retrospective registration cancellation and consequential donation approval rejection cannot stand
    July 14, 2026   Case Laws Income Tax
    Medical relief remains charitable despite premium hospital operations; statutory enquiry focuses on genuine activities and application of income.
    July 14, 2026   Case Laws Income Tax
    Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verification
    July 14, 2026   Case Laws Income Tax
    Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised trading tests
    July 14, 2026   Case Laws Income Tax
    Lease deed stamp duty is revenue expenditure when it secures business use, preventing later capitalisation, amortisation, or depreciation claims.
    July 14, 2026   Case Laws Income Tax
    Combined TNMM benchmarking bars separate royalty and GAM adjustments when those costs are embedded in the tested segment's operating base
    July 14, 2026   Case Laws Income Tax
    Reasonable cause limits transfer-pricing penalties, while appellate enhancement cannot extend proceedings to transactions never included in initiation
    July 14, 2026   Case Laws Customs
    Statutory admission screening limits respondent intervention, deferring maintainability and jurisdiction objections to the post-admission hearing.
    July 14, 2026   Case Laws SEBI
    Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or penalties

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

      The Appellate Tribunal considered Transfer Pricing adjustment...

      Appellate Tribunal Rules in Favor of Assessee on Transfer Pricing, Cites Section 80-IA(8) for Inter-Unit Power Transfers.

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      Income TaxJune 20, 2024Case LawsAT
      The Appellate Tribunal considered Transfer Pricing adjustment u/s 92 for inter-unit power transfer. TPO rejected TP report, comparing sale prices with GEB. Tribunal favored assessee, citing GEB's price as correct comparison u/s 80-IA(8). TPL not valid for CUP. Admitted additional ground on deduction u/s 80-IA for steam transfer at market value. Assessee's reasonable cause accepted. Matter remitted to AO for fresh assessment on market value of steam for 80-IA deduction. Relevant legal principles u/s 80-IA and admission of additional grounds were considered in line with Supreme Court decisions.
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