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    July 21, 2026   Case LawsIncome Tax
    Residential property investment under Section 54F remains eligible despite delayed completion, possession or registration beyond the taxpayer's contro...
    July 21, 2026   Case LawsIncome Tax
    Royalty benchmarking under TNMM prevails where domestic rates lack reliable comparability for export transactions and technical know-how use.
    July 21, 2026   Case LawsIncome Tax
    Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
    July 21, 2026   Case LawsIncome Tax
    Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
    July 21, 2026   Case LawsIncome Tax
    Statutory approval under reassessment rules is jurisdictional; sanction by an incompetent authority invalidates the notice and reassessment.
    July 21, 2026   Case LawsIncome Tax
    Insurance compensation adjusted against fire loss cannot be separately taxed, and the consequential concealment penalty fails.
    July 21, 2026   Case LawsIncome Tax
    Securitisation trust pass-through taxation applies where investors lack voluntary common design and retain revocation rights over contributions.
    July 21, 2026   Case LawsIncome Tax
    Mandatory prior notice for bank-account attachment requires release where the assessee was not informed before recovery action.
    July 21, 2026   Case LawsIncome Tax
    Bona fide cash accounting for unpaid loan interest permits exclusion of accrued but unrealised income when consistently disclosed.
    July 21, 2026   Case LawsBenami Property
    Doctrine of election barred inconsistent ownership claims, while testamentary office permission created no life interest or possessory right.
    July 21, 2026   Case LawsCustoms
    Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
    July 21, 2026   Case LawsCustoms
    Aluminium formwork classification turns on its on-site shuttering function, supporting treatment as aluminium structures rather than moulds.
    July 21, 2026   Case LawsCustoms
    Aluminium formwork used as concrete shuttering is classified as aluminium structures, not as moulds for concrete articles.
    July 21, 2026   Case LawsCustoms
    Customs valuation: proven under-invoicing sustains duty and confiscation, while provisional assessments require lawful finalisation before consequenti...
    July 21, 2026   Case LawsCustoms
    Sole or principal use classification placed imported floating seals under machinery-parts heading, defeating extended-period customs consequences.
    July 21, 2026   Case LawsCustoms
    Roasted nut classification follows specific Chapter 20 entries, while preferential duty depends on establishing prescribed originating status.
    July 21, 2026   Case LawsCustoms
    Semi-manufactured gold classification under Heading 7108 permits conditional ASEAN tariff preference without displacing separate import-policy restric...
    July 21, 2026   Case LawsIBC
    Section 7 insolvency admission proceeds despite unfinalised compromise proposals, settlement talks and pending counterclaims where financial debt and ...
    July 21, 2026   Case LawsIBC
    Proportional disciplinary suspension requires hearings on unrelated assignments; creditor committees retain discretion to replace resolution professio...
    July 21, 2026   Case LawsIBC
    Limitation for insolvency applications defeated proceedings despite valid partner authorisation and advances qualifying as financial debt.
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    July 21, 2026   Case Laws Income Tax
    Residential property investment under Section 54F remains eligible despite delayed completion, possession or registration beyond the taxpayer's control.
    July 21, 2026   Case Laws Income Tax
    Royalty benchmarking under TNMM prevails where domestic rates lack reliable comparability for export transactions and technical know-how use.
    July 21, 2026   Case Laws Income Tax
    Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any adjustment.
    July 21, 2026   Case Laws Income Tax
    Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classification.
    July 21, 2026   Case Laws Income Tax
    Statutory approval under reassessment rules is jurisdictional; sanction by an incompetent authority invalidates the notice and reassessment.
    July 21, 2026   Case Laws Income Tax
    Insurance compensation adjusted against fire loss cannot be separately taxed, and the consequential concealment penalty fails.
    July 21, 2026   Case Laws Income Tax
    Securitisation trust pass-through taxation applies where investors lack voluntary common design and retain revocation rights over contributions.
    July 21, 2026   Case Laws Income Tax
    Mandatory prior notice for bank-account attachment requires release where the assessee was not informed before recovery action.
    July 21, 2026   Case Laws Income Tax
    Bona fide cash accounting for unpaid loan interest permits exclusion of accrued but unrealised income when consistently disclosed.
    July 21, 2026   Case Laws Benami Property
    Doctrine of election barred inconsistent ownership claims, while testamentary office permission created no life interest or possessory right.
    July 21, 2026   Case Laws Customs
    Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutiny.
    July 21, 2026   Case Laws Customs
    Aluminium formwork classification turns on its on-site shuttering function, supporting treatment as aluminium structures rather than moulds.
    July 21, 2026   Case Laws Customs
    Aluminium formwork used as concrete shuttering is classified as aluminium structures, not as moulds for concrete articles.
    July 21, 2026   Case Laws Customs
    Customs valuation: proven under-invoicing sustains duty and confiscation, while provisional assessments require lawful finalisation before consequential demands.
    July 21, 2026   Case Laws Customs
    Sole or principal use classification placed imported floating seals under machinery-parts heading, defeating extended-period customs consequences.
    July 21, 2026   Case Laws Customs
    Roasted nut classification follows specific Chapter 20 entries, while preferential duty depends on establishing prescribed originating status.
    July 21, 2026   Case Laws Customs
    Semi-manufactured gold classification under Heading 7108 permits conditional ASEAN tariff preference without displacing separate import-policy restrictions.
    July 21, 2026   Case Laws IBC
    Section 7 insolvency admission proceeds despite unfinalised compromise proposals, settlement talks and pending counterclaims where financial debt and default stand established.
    July 21, 2026   Case Laws IBC
    Proportional disciplinary suspension requires hearings on unrelated assignments; creditor committees retain discretion to replace resolution professionals.
    July 21, 2026   Case Laws IBC
    Limitation for insolvency applications defeated proceedings despite valid partner authorisation and advances qualifying as financial debt.

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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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