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    July 23, 2026   Case LawsIncome Tax
    Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
    July 23, 2026   Case LawsIncome Tax
    Redeveloped flat holding period follows original ownership rights, supporting long-term capital gains, indexed cost and residential-house exemption.
    July 23, 2026   Case LawsIncome Tax
    Dependent agent permanent establishment attribution was deleted, while unexamined refund interest required fresh consideration after adequate hearing.
    July 23, 2026   Case LawsIncome Tax
    Profit embedded in unaccounted business receipts was taxed at a 1% gross-profit rate; unsupported salary and asset additions failed.
    July 23, 2026   Case LawsIncome Tax
    Effective opportunity to explain foreign bank credits required remand for fresh appellate consideration with supporting evidence.
    July 23, 2026   Case LawsIncome Tax
    Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
    July 23, 2026   Case LawsIncome Tax
    Related-party interest deductions require excess over fair market value, while unsupported software and brokerage claims remain disallowable.
    July 23, 2026   Case LawsIncome Tax
    Scope of reassessment restricts unrelated additions when the recorded escapement issue is accepted without any addition.
    July 23, 2026   Case LawsIncome Tax
    Capital-gains exemption for under-construction flats remains available despite developer delay and may be admitted despite return-form omission.
    July 23, 2026   Case LawsIncome Tax
    Holding period of flat allotment rights runs from reservation, supporting long-term capital gain and indexation on surrender.
    July 23, 2026   Case LawsIncome Tax
    Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
    July 23, 2026   Case LawsIncome Tax
    Bona fide property-sale receipts supported by records may avoid cash-transaction penalties where genuineness and identity are established.
    July 23, 2026   Case LawsIncome Tax
    Satisfactory source evidence for foreign assets prevents their treatment as undisclosed assets and removes consequential Black Money Act penalty.
    July 23, 2026   Case LawsCustoms
    Customs exemption for EOU manufacturing inputs survives excess waste when authorised clearance occurs on payment of applicable duty.
    July 23, 2026   Case LawsCustoms
    Intentional aid is essential for abetment; a Customs House Agent employee need not verify customs-sealed container contents.
    July 23, 2026   Case LawsCustoms
    Bill of entry amendment remains available where loss evidence predates final clearance for home consumption after provisional assessment.
    July 23, 2026   Case LawsCustoms
    Provisional release security was moderated for non-IPR garments, with full bond retained pending provisional assessment.
    July 23, 2026   Case LawsCustoms
    Blood glucose monitoring systems fall under chemical analysis instruments, displacing classification as general medical and surgical instruments.
    July 23, 2026   Case LawsFEMA
    Discretionary confiscation under FEMA requires a reasoned factual exercise and is not automatic alongside monetary penalties.
    July 23, 2026   Case LawsMoney Laundering
    Distinct money-laundering offence permits PMLA prosecution after predicate-offence conviction; double jeopardy does not apply.
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    July 23, 2026   Case Laws Income Tax
    Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years.
    July 23, 2026   Case Laws Income Tax
    Redeveloped flat holding period follows original ownership rights, supporting long-term capital gains, indexed cost and residential-house exemption.
    July 23, 2026   Case Laws Income Tax
    Dependent agent permanent establishment attribution was deleted, while unexamined refund interest required fresh consideration after adequate hearing.
    July 23, 2026   Case Laws Income Tax
    Profit embedded in unaccounted business receipts was taxed at a 1% gross-profit rate; unsupported salary and asset additions failed.
    July 23, 2026   Case Laws Income Tax
    Effective opportunity to explain foreign bank credits required remand for fresh appellate consideration with supporting evidence.
    July 23, 2026   Case Laws Income Tax
    Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded.
    July 23, 2026   Case Laws Income Tax
    Related-party interest deductions require excess over fair market value, while unsupported software and brokerage claims remain disallowable.
    July 23, 2026   Case Laws Income Tax
    Scope of reassessment restricts unrelated additions when the recorded escapement issue is accepted without any addition.
    July 23, 2026   Case Laws Income Tax
    Capital-gains exemption for under-construction flats remains available despite developer delay and may be admitted despite return-form omission.
    July 23, 2026   Case Laws Income Tax
    Holding period of flat allotment rights runs from reservation, supporting long-term capital gain and indexation on surrender.
    July 23, 2026   Case Laws Income Tax
    Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act additions.
    July 23, 2026   Case Laws Income Tax
    Bona fide property-sale receipts supported by records may avoid cash-transaction penalties where genuineness and identity are established.
    July 23, 2026   Case Laws Income Tax
    Satisfactory source evidence for foreign assets prevents their treatment as undisclosed assets and removes consequential Black Money Act penalty.
    July 23, 2026   Case Laws Customs
    Customs exemption for EOU manufacturing inputs survives excess waste when authorised clearance occurs on payment of applicable duty.
    July 23, 2026   Case Laws Customs
    Intentional aid is essential for abetment; a Customs House Agent employee need not verify customs-sealed container contents.
    July 23, 2026   Case Laws Customs
    Bill of entry amendment remains available where loss evidence predates final clearance for home consumption after provisional assessment.
    July 23, 2026   Case Laws Customs
    Provisional release security was moderated for non-IPR garments, with full bond retained pending provisional assessment.
    July 23, 2026   Case Laws Customs
    Blood glucose monitoring systems fall under chemical analysis instruments, displacing classification as general medical and surgical instruments.
    July 23, 2026   Case Laws FEMA
    Discretionary confiscation under FEMA requires a reasoned factual exercise and is not automatic alongside monetary penalties.
    July 23, 2026   Case Laws Money Laundering
    Distinct money-laundering offence permits PMLA prosecution after predicate-offence conviction; double jeopardy does not apply.

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

      Determination of arm's length price (ALP) for international...

      Evaluating Comparable Companies for Arm's Length Price in International Deals: Key Criteria and Profit Indicators.

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      Income TaxOctober 23, 2024Case LawsAT
      Determination of arm's length price (ALP) for international transactions, focusing on the selection of comparable companies. It excludes companies like Elofic Industries Ltd., WABCO TVS (India) Ltd., Brakes India Pvt. Ltd., Clutch Auto Ltd., ANG Industries Ltd., and Sundram Brake Linings Ltd. as functionally dissimilar or operating in different markets. It also discusses the inclusion/exclusion of Faiveley Transport Rail Technologies India Ltd., XLO India Ltd., and Rane Brake Lining Ltd. based on specific criteria. Additionally, it addresses the treatment of foreign exchange gains as operating income and the consideration of cash profit/operating income as a profit level indicator, citing relevant case laws. The summary covers the key issues related to comparable selection and ALP determination in a concise manner.
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      ActsIncome Tax
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