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    April 24, 2026   Case Laws Income Tax
    Integrated business model accepted for transfer pricing, with entity-level TNMM applied instead of separate segment benchmarking.
    April 24, 2026   Case Laws Income Tax
    Notional valuation cannot justify export sales addition when declared exports are genuine and no extra consideration is proved.
    April 24, 2026   Case Laws Income Tax
    CSR donations can still qualify for section 80G relief; receivables adjustment and other issues were remanded.
    April 24, 2026   Case Laws Income Tax
    Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
    April 24, 2026   Case Laws Income Tax
    TNMM accepted for intra-group services and SAP costs, while provident fund disallowance under employee contribution was sustained.
    April 24, 2026   Case Laws Income Tax
    Section 43CA does not cover TDR transfers, as development rights are not land or building; addition deleted.
    April 24, 2026   Case Laws Income Tax
    Stock-in-trade land sale cannot attract section 50C where the transaction is already accepted as business income.
    April 24, 2026   Case Laws Income Tax
    Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
    April 24, 2026   Case Laws Income Tax
    Retrospective omission of specified domestic transaction provision invalidated transfer pricing adjustment and confirmed SEZ deduction eligibility.
    April 24, 2026   Case Laws Income Tax
    Statutory exemption for Agricultural Produce Marketing Committee income cannot be denied because of an incorrect PAN status entry.
    April 24, 2026   Case Laws Income Tax
    Amalgamation bars continuation of tax deductions under sections 80IA and 80JJAA when business is transferred by reorganisation.
    April 24, 2026   Case Laws Income Tax
    Article 8 India-France DTAA: collection charges taxable, while technical handling income, interest and commission stayed within treaty protection.
    April 24, 2026   Case Laws Customs
    Alternate remedy bars customs writs; non-communication of time extension under Section 28(9) was not fatal.
    April 24, 2026   Case Laws Customs
    Preferential duty benefit under a free trade agreement cannot rest on a superseded public notice; reassessment ordered.
    April 24, 2026   Case Laws Customs
    DIN compliance in departmental orders is mandatory; an order issued without it was set aside and remanded.
    April 24, 2026   Case Laws Customs
    Strict construction of customs exemption and prospective IGST interest levy shape duty, classification, and penalty relief.
    April 24, 2026   Case Laws Customs
    Declared value, re-assessment, and confiscation principles: Tribunal upholds value redetermination but rejects section 28 recovery and penalty.
    April 24, 2026   Case Laws Customs
    Cross-examination and corroboration are essential before penalty for alleged smuggling facilitation can be sustained.
    April 24, 2026   Case Laws Customs
    Mistake apparent from record was not shown in provisional release conditions; rectification was refused, with clarification left open.
    April 24, 2026   Case Laws Companies Law
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April 24, 2026   Case Laws Income Tax
Integrated business model accepted for transfer pricing, with entity-level TNMM applied instead of separate segment benchmarking.
April 24, 2026   Case Laws Income Tax
Notional valuation cannot justify export sales addition when declared exports are genuine and no extra consideration is proved.
April 24, 2026   Case Laws Income Tax
CSR donations can still qualify for section 80G relief; receivables adjustment and other issues were remanded.
April 24, 2026   Case Laws Income Tax
Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocation.
April 24, 2026   Case Laws Income Tax
TNMM accepted for intra-group services and SAP costs, while provident fund disallowance under employee contribution was sustained.
April 24, 2026   Case Laws Income Tax
Section 43CA does not cover TDR transfers, as development rights are not land or building; addition deleted.
April 24, 2026   Case Laws Income Tax
Stock-in-trade land sale cannot attract section 50C where the transaction is already accepted as business income.
April 24, 2026   Case Laws Income Tax
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inadequate.
April 24, 2026   Case Laws Income Tax
Retrospective omission of specified domestic transaction provision invalidated transfer pricing adjustment and confirmed SEZ deduction eligibility.
April 24, 2026   Case Laws Income Tax
Statutory exemption for Agricultural Produce Marketing Committee income cannot be denied because of an incorrect PAN status entry.
April 24, 2026   Case Laws Income Tax
Amalgamation bars continuation of tax deductions under sections 80IA and 80JJAA when business is transferred by reorganisation.
April 24, 2026   Case Laws Income Tax
Article 8 India-France DTAA: collection charges taxable, while technical handling income, interest and commission stayed within treaty protection.
April 24, 2026   Case Laws Customs
Alternate remedy bars customs writs; non-communication of time extension under Section 28(9) was not fatal.
April 24, 2026   Case Laws Customs
Preferential duty benefit under a free trade agreement cannot rest on a superseded public notice; reassessment ordered.
April 24, 2026   Case Laws Customs
DIN compliance in departmental orders is mandatory; an order issued without it was set aside and remanded.
April 24, 2026   Case Laws Customs
Strict construction of customs exemption and prospective IGST interest levy shape duty, classification, and penalty relief.
April 24, 2026   Case Laws Customs
Declared value, re-assessment, and confiscation principles: Tribunal upholds value redetermination but rejects section 28 recovery and penalty.
April 24, 2026   Case Laws Customs
Cross-examination and corroboration are essential before penalty for alleged smuggling facilitation can be sustained.
April 24, 2026   Case Laws Customs
Mistake apparent from record was not shown in provisional release conditions; rectification was refused, with clarification left open.
April 24, 2026   Case Laws Companies Law
Res judicata and continuing liquidation justified retention of premises; no summary order could compel surrender of tenancy rights.

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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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