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    July 16, 2026   Case LawsIncome Tax
    Share premium valuation requires examination of supporting reports, while limited scrutiny restricts additions beyond the selected issues.
    July 16, 2026   Case LawsIncome Tax
    Revision limitation for issues outside reassessment runs from the original assessment, rendering delayed revision proceedings time-barred.
    July 16, 2026   Case LawsIncome Tax
    Per-payment TDS threshold limits online gaming withholding, while unclaimed player payouts cannot trigger expenditure disallowance under tax law.
    July 16, 2026   Case LawsIncome Tax
    Section 87A rebate remains available against short-term capital gains where the relevant law contained no express exclusion.
    July 16, 2026   Case LawsIncome Tax
    Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
    July 16, 2026   Case LawsIncome Tax
    Estimated business expenditure for unsupported commission expenses increased after considering the nature and circumstances of commission activities.
    July 16, 2026   Case LawsIncome Tax
    Intra-group software licence costs require evidence of actual use, while comparable selection must reflect functional and scale differences.
    July 16, 2026   Case LawsCustoms
    Reasonable-time limits on duty drawback recovery bar unexplained delayed proceedings where fraud or suppression is not alleged.
    July 16, 2026   Case LawsCustoms
    Specific LCD tariff classification prevails over end-use based controller classification, requiring fresh determination under Chapter 90.
    July 16, 2026   Case LawsCustoms
    Provisional release for re-export remains available pending unresolved classification, despite alleged import restrictions on seized goods.
    July 16, 2026   Case LawsCustoms
    Strict construction of customs exemptions denies ELISA-kit duty concession to separately imported QFT Tube components.
    July 16, 2026   Case LawsCustoms
    Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
    July 16, 2026   Case LawsIBC
    Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
    July 16, 2026   Case LawsIBC
    Leasehold BOT rights can be liquidated as going-concern assets while preserving landowner rights and end-of-concession transfer obligations.
    July 16, 2026   Case LawsIBC
    Contractual development rights may be insolvency assets, but resolution plans cannot override third-party land title or statutory approvals.
    July 16, 2026   Case LawsMoney Laundering
    Territorial jurisdiction under PMLA may be concurrent, allowing transfer to align money-laundering proceedings with the connected scheduled offence.
    July 16, 2026   Case LawsMoney Laundering
    Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
    July 16, 2026   Case LawsService Tax
    Pan-India service-tax investigation powers extend beyond local limits, while pre-notice consultation remains recommendatory under departmental guidanc...
    July 16, 2026   Case LawsService Tax
    Documentary proof of service-tax payment governs refund eligibility, while delayed-refund interest runs only after the statutory waiting period.
    July 16, 2026   Case LawsWealth-tax
    Specialised agricultural valuation qualifications validly distinguish expertise in land, crop and soil assessment from other professional credentials.
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    July 16, 2026   Case Laws Income Tax
    Share premium valuation requires examination of supporting reports, while limited scrutiny restricts additions beyond the selected issues.
    July 16, 2026   Case Laws Income Tax
    Revision limitation for issues outside reassessment runs from the original assessment, rendering delayed revision proceedings time-barred.
    July 16, 2026   Case Laws Income Tax
    Per-payment TDS threshold limits online gaming withholding, while unclaimed player payouts cannot trigger expenditure disallowance under tax law.
    July 16, 2026   Case Laws Income Tax
    Section 87A rebate remains available against short-term capital gains where the relevant law contained no express exclusion.
    July 16, 2026   Case Laws Income Tax
    Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protection.
    July 16, 2026   Case Laws Income Tax
    Estimated business expenditure for unsupported commission expenses increased after considering the nature and circumstances of commission activities.
    July 16, 2026   Case Laws Income Tax
    Intra-group software licence costs require evidence of actual use, while comparable selection must reflect functional and scale differences.
    July 16, 2026   Case Laws Customs
    Reasonable-time limits on duty drawback recovery bar unexplained delayed proceedings where fraud or suppression is not alleged.
    July 16, 2026   Case Laws Customs
    Specific LCD tariff classification prevails over end-use based controller classification, requiring fresh determination under Chapter 90.
    July 16, 2026   Case Laws Customs
    Provisional release for re-export remains available pending unresolved classification, despite alleged import restrictions on seized goods.
    July 16, 2026   Case Laws Customs
    Strict construction of customs exemptions denies ELISA-kit duty concession to separately imported QFT Tube components.
    July 16, 2026   Case Laws Customs
    Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequential relief.
    July 16, 2026   Case Laws IBC
    Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and related show-cause notice.
    July 16, 2026   Case Laws IBC
    Leasehold BOT rights can be liquidated as going-concern assets while preserving landowner rights and end-of-concession transfer obligations.
    July 16, 2026   Case Laws IBC
    Contractual development rights may be insolvency assets, but resolution plans cannot override third-party land title or statutory approvals.
    July 16, 2026   Case Laws Money Laundering
    Territorial jurisdiction under PMLA may be concurrent, allowing transfer to align money-laundering proceedings with the connected scheduled offence.
    July 16, 2026   Case Laws Money Laundering
    Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitation.
    July 16, 2026   Case Laws Service Tax
    Pan-India service-tax investigation powers extend beyond local limits, while pre-notice consultation remains recommendatory under departmental guidance.
    July 16, 2026   Case Laws Service Tax
    Documentary proof of service-tax payment governs refund eligibility, while delayed-refund interest runs only after the statutory waiting period.
    July 16, 2026   Case Laws Wealth-tax
    Specialised agricultural valuation qualifications validly distinguish expertise in land, crop and soil assessment from other professional credentials.

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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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