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    October 14, 2026   Case Laws GST
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October 14, 2026   Case Laws GST
Effective hearing rights prevent same-day confiscation orders when authorities grant time for a written response.
October 14, 2026   Case Laws GST
Statutory limits on GST appeal delay condonation remain binding, while restored registrations can make departmental challenges infructuous.
October 14, 2026   Case Laws Central Excise
Delayed judgment pronouncement alone does not invalidate Tribunal orders, while rectification cannot reopen evidence or negate confiscation-related penalties.
October 14, 2026   Case Laws Income Tax
Philanthropic hospital approval turns on medical-purpose application of funds, not revenue surplus or free-treatment ratios alone.
October 14, 2026   Case Laws Income Tax
Prospective software royalty clarification prevents tax-deduction disallowance for pre-effective-date licence renewals, while payable includes paid sums.
October 14, 2026   Case Laws Income Tax
Functional comparability requires data-driven analysis; outsourcing justified exclusion where no perversity undermined the Tribunal's factual findings.
October 14, 2026   Case Laws Income Tax
Limited scrutiny limits inquiries to notified issues, requiring deletion of an in-house R&D deduction disallowance beyond scope.
October 14, 2026   Case Laws Income Tax
Agricultural-land reinvestment qualifies when transfer consideration precedes replacement purchase, while unexamined claims may be reassessed on escaped-income grounds.
October 14, 2026   Case Laws Income Tax
Bona fide public fixed-deposit explanations prevent concealment penalties where unexplained-credit additions lack independent evidence of undisclosed income.
October 14, 2026   Case Laws Income Tax
Interest on excess refunds cannot be charged where reassessment follows an earlier scrutiny assessment rather than being the first assessment.
October 14, 2026   Case Laws Income Tax
Genuine political contributions require credible evidence beyond banking records; unsupported claims can lose deductions and penalty challenges remain premature.
October 14, 2026   Case Laws Income Tax
Misreporting penalty requires assessee-specific proof of accommodation-entry participation; donation deduction withdrawal alone cannot justify enhanced penalty.
October 14, 2026   Case Laws Income Tax
Safe-harbour tolerance for stamp-duty valuation applies retrospectively and prevents deemed income additions for marginal property-value differences.
October 14, 2026   Case Laws Customs
QCO exemption for steel imports applies when shipment met the cut-off and ARN was timely sought under SIMS.
October 14, 2026   Case Laws Customs
Statutory conclusion of customs proceedings bars later confiscation, redemption fine and penalty after timely payment of notified dues.
October 14, 2026   Case Laws Customs
Confiscation in rem survives, but customs penalties require proof that consignees knowingly participated in concealed imports.
October 14, 2026   Case Laws Customs
Tariff classification of anti-theft steering locks excludes the steering-system entry, defeating reclassification, confiscation, extended limitation, and penalties.
October 14, 2026   Case Laws Customs
Alternative Customs Classification Claims Require Merits Review; Unavailable Goods Bar Redemption Fine and Bona Fide Claims Avoid Penalty.
October 14, 2026   Case Laws Customs
Co-accused statements and WhatsApp chats require corroboration and cross-examination before they can support customs penalties.
October 14, 2026   Case Laws Customs
Duplicate customs duty payment through portal error is excess collection, placing its refund outside statutory limitation.

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

The Appellate Tribunal ruled on Transfer Pricing Adjustment,...

Tribunal Adjusts Transfer Pricing: Excludes High Turnover Firms; Benchmarks Trade Receivables Interest at 6% SBI Rate.

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Income Tax June 26, 2024 Case Laws AT
The Appellate Tribunal ruled on Transfer Pricing Adjustment, excluding companies with high turnover from comparables. Companies like Larsen & Toubro Infotech Ltd., Tata Elxsi Ltd., Persistent Systems Ltd., Aspire Systems Pvt. Ltd., and Infosys Ltd. were deemed incomparable due to substantial turnover difference. Infobeans Technologies Ltd. and Thirdware Solution Ltd. were considered comparable. Cigniti Technologies Ltd. was excluded for not meeting export revenue filter. Certain companies requested for inclusion were remanded for further assessment. Regarding interest on trade receivables, the Tribunal considered it an international transaction, benchmarking at 6% SBI rate due to lack of evidence on extended credit period. The appeal was partly allowed for statistical purposes.
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Acts Income Tax
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