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    April 28, 2026   Case Laws Income Tax
    Rule 46A compliance requires a speaking order and opportunity to rebut before additional evidence is used in appeal.
    April 28, 2026   Case Laws Income Tax
    Share valuation under section 56(2)(viib) must be done afresh for each issue of unquoted equity shares, the ITAT held.
    April 28, 2026   Case Laws Income Tax
    Section 10AA, bad debts and section 41(1) rulings turn on export proof, write-off evidence and capital liability adjustment.
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    DCF share valuation cannot be replaced without defect; protective addition fails when taxability uncertainty is absent.
    April 28, 2026   Case Laws Income Tax
    Place of effective management must rest on proved facts, not institutional deference; global income addition deleted.
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    Permanent establishment through branch office continuity led to remand for fresh profit attribution and taxability review.
    April 28, 2026   Case Laws Income Tax
    Section 87A rebate applies under the new tax regime even where tax arises on short-term capital gains under section 111A.
    April 28, 2026   Case Laws Income Tax
    Protective assessment and TDS credit issues remanded for fresh verification of ownership, exemption eligibility, and income nexus.
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April 28, 2026   Case Laws Income Tax
Rule 46A compliance requires a speaking order and opportunity to rebut before additional evidence is used in appeal.
April 28, 2026   Case Laws Income Tax
Share valuation under section 56(2)(viib) must be done afresh for each issue of unquoted equity shares, the ITAT held.
April 28, 2026   Case Laws Income Tax
Section 10AA, bad debts and section 41(1) rulings turn on export proof, write-off evidence and capital liability adjustment.
April 28, 2026   Case Laws Income Tax
Common area maintenance recoveries justify business expenditure allowance and limit apportionment against rental income claims.
April 28, 2026   Case Laws Income Tax
DCF share valuation cannot be replaced without defect; protective addition fails when taxability uncertainty is absent.
April 28, 2026   Case Laws Income Tax
Place of effective management must rest on proved facts, not institutional deference; global income addition deleted.
April 28, 2026   Case Laws Income Tax
Permanent establishment through branch office continuity led to remand for fresh profit attribution and taxability review.
April 28, 2026   Case Laws Income Tax
Section 87A rebate applies under the new tax regime even where tax arises on short-term capital gains under section 111A.
April 28, 2026   Case Laws Income Tax
Protective assessment and TDS credit issues remanded for fresh verification of ownership, exemption eligibility, and income nexus.
April 28, 2026   Case Laws Income Tax
Arm's length remuneration for a dependent agent PE bars further profit attribution under Rule 10.
April 28, 2026   Case Laws Customs
Natural justice and customs broker liability: penalty set aside for lack of factual findings and ignored binding precedents.
April 28, 2026   Case Laws Customs
Customs penalty for smuggled gold sustained where notice clearly set out abetment, dealing, and prohibited-goods liability.
April 28, 2026   Case Laws Customs
Penalty under Section 112 fails where knowledge, admissible statements, and incriminating evidence are not proved against the Customs Broker's director.
April 28, 2026   Case Laws Customs
Prospective amendment to customs IGST law barred interest, redemption fine and penalty for the unamended period.
April 28, 2026   Case Laws Customs
Classification of food seasoning as a mixture of odoriferous substances upheld; reclassification under a food preparations heading rejected.
April 28, 2026   Case Laws Customs
Technical classification of imported goods as limestone justified denial of marble exemption, confiscation, and penalties.
April 28, 2026   Case Laws Companies Law
Statutory inquiry and fraud threshold: defective inspection report and unsupported SFIO investigation were both quashed.
April 28, 2026   Case Laws Companies Law
Condonation of delay in share transfer disputes upheld where illness-based explanation and medical evidence showed sufficient cause.
April 28, 2026   Case Laws IBC
Provident fund protection in liquidation excludes employee dues from the estate and blocks waterfall distribution.
April 28, 2026   Case Laws IBC
Pre-existing dispute defeats insolvency claim; disputed advance refund and forfeiture kept Section 9 petition out of time.

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Income Tax

The Appellate Tribunal held that negative working capital...

Appellate Tribunal Excludes Multiple Companies from Comparables in Transfer Pricing Case for Captive Service Provider.

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Income Tax June 28, 2024 Case Laws AT
The Appellate Tribunal held that negative working capital adjustment cannot be made for a captive service provider. L&T Infotech Ltd. and Infosys Ltd. were excluded from comparables as the assessee is a captive service provider compensated on a cost+mark-up basis. Persistent Systems Ltd. was excluded due to lack of segmental details. Infobeans Technologies Ltd. was found not functionally comparable. Tata Elxsi Ltd. was excluded as it generates revenue from product sales. Mindtree Ltd. & Nihilent Ltd. lacked segmental financials. Cygnet Infotech Pvt. Ltd. was excluded for not being a captive service provider. Cybage Software Pvt. Ltd. was excluded due to diversified activities. Batchmaster Software Pvt. Ltd. was remanded for further verification. The issue of deduction u/s. 10AA and interest levy u/s. 234A, 234B, 234C requires verification by the assessing officer based on evidence provided by the assessee.
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Acts Income Tax
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