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    September 25, 2026   Case Laws Income Tax
    Stamp valuation increases after registration-fee payment led to deletion of property-purchase addition within tolerance and without valuation referral...
    September 25, 2026   Case Laws Income Tax
    Recurring advertising expenditure remains revenue in nature where it creates no capital asset or enduring benefit.
    September 25, 2026   Case Laws Income Tax
    Agricultural Land Capital-Asset Status Requires Proof of Municipal Limits Before Capital Gains and Exemption Claims Are Decided
    September 25, 2026   Case Laws Income Tax
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    September 25, 2026   Case Laws Income Tax
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    September 25, 2026   Case Laws Income Tax
    Foreign tax credit survives delayed prescribed-form filing where no rule prescribes denial, permitting rectification of contradictory computations.
    September 25, 2026   Case Laws Income Tax
    Survey statements need corroboration for unexplained money additions; genuine tax audit report uploading delays can avoid penalty.
    September 25, 2026   Case Laws Income Tax
    Stamp-duty valuation alone cannot establish concealment when disclosed purchase records remain undisputed for penalty purposes.
    September 25, 2026   Case Laws Income Tax
    Under-reported income penalties require consideration of bona fide explanation, full disclosure, and statutory discretion before imposition.
    September 25, 2026   Case Laws Income Tax
    Ambiguous reassessment notices and mismatched approval amounts invalidate proceedings for lack of application of mind.
    September 25, 2026   Case Laws Income Tax
    Capital Asset Conversion Requires Proven Business Stock Treatment; Paper Consideration in Spousal Flat Transfers Does Not Create Taxable Business Inco...
    September 25, 2026   Case Laws Income Tax
    Consistency between reassessment notice and recorded satisfaction bars additions founded on a different explanation for land investment.
    September 25, 2026   Case Laws Income Tax
    Scrutiny notice format defects remain curable, while untested appellate evidence requires a fresh reasoned assessment after fair examination.
    September 25, 2026   Case Laws Income Tax
    Tax deduction on interest applies only upon current-year credit or payment, while real income requires actual accrual.
    September 25, 2026   Case Laws Income Tax
    Human-probability test defeats political donation deduction where banking records mask accommodation-entry fund layering and evidence shows non-genuin...
    September 25, 2026   Case Laws Income Tax
    Slump-sale valuation under the prescribed method cannot be replaced without identified defects, and proper show-cause notice remains mandatory.
    September 25, 2026   Case Laws Income Tax
    Commercial property status protects capital-gains exemption when residential-house ownership limits are tested, while agricultural-land character gove...
    September 25, 2026   Case Laws Customs
    Electronic correction of Reward declarations enables timely transmission of amended shipping bills for MEIS benefit processing.
    September 25, 2026   Case Laws Customs
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September 25, 2026   Case Laws Income Tax
Stamp valuation increases after registration-fee payment led to deletion of property-purchase addition within tolerance and without valuation referral.
September 25, 2026   Case Laws Income Tax
Recurring advertising expenditure remains revenue in nature where it creates no capital asset or enduring benefit.
September 25, 2026   Case Laws Income Tax
Agricultural Land Capital-Asset Status Requires Proof of Municipal Limits Before Capital Gains and Exemption Claims Are Decided
September 25, 2026   Case Laws Income Tax
Unrecorded sales receipts: profit estimates require evidentiary basis, while off-book entries cannot trigger cash-credit additions.
September 25, 2026   Case Laws Income Tax
Best-judgment expenditure disallowances need material evidence; book rejection alone cannot justify an unsupported ad hoc addition.
September 25, 2026   Case Laws Income Tax
Foreign tax credit survives delayed prescribed-form filing where no rule prescribes denial, permitting rectification of contradictory computations.
September 25, 2026   Case Laws Income Tax
Survey statements need corroboration for unexplained money additions; genuine tax audit report uploading delays can avoid penalty.
September 25, 2026   Case Laws Income Tax
Stamp-duty valuation alone cannot establish concealment when disclosed purchase records remain undisputed for penalty purposes.
September 25, 2026   Case Laws Income Tax
Under-reported income penalties require consideration of bona fide explanation, full disclosure, and statutory discretion before imposition.
September 25, 2026   Case Laws Income Tax
Ambiguous reassessment notices and mismatched approval amounts invalidate proceedings for lack of application of mind.
September 25, 2026   Case Laws Income Tax
Capital Asset Conversion Requires Proven Business Stock Treatment; Paper Consideration in Spousal Flat Transfers Does Not Create Taxable Business Income.
September 25, 2026   Case Laws Income Tax
Consistency between reassessment notice and recorded satisfaction bars additions founded on a different explanation for land investment.
September 25, 2026   Case Laws Income Tax
Scrutiny notice format defects remain curable, while untested appellate evidence requires a fresh reasoned assessment after fair examination.
September 25, 2026   Case Laws Income Tax
Tax deduction on interest applies only upon current-year credit or payment, while real income requires actual accrual.
September 25, 2026   Case Laws Income Tax
Human-probability test defeats political donation deduction where banking records mask accommodation-entry fund layering and evidence shows non-genuine contributions.
September 25, 2026   Case Laws Income Tax
Slump-sale valuation under the prescribed method cannot be replaced without identified defects, and proper show-cause notice remains mandatory.
September 25, 2026   Case Laws Income Tax
Commercial property status protects capital-gains exemption when residential-house ownership limits are tested, while agricultural-land character governs reinvestment relief.
September 25, 2026   Case Laws Customs
Electronic correction of Reward declarations enables timely transmission of amended shipping bills for MEIS benefit processing.
September 25, 2026   Case Laws Customs
Tariff reclassification burden required article-specific evidence, defeating extended limitation, confiscation, and penalties for imported vehicle parts.
September 25, 2026   Case Laws Customs
Section 28 Recovery: unpaid anti-dumping duty may be demanded without overturning self-assessment; IGST and contemporaneous penalty limits apply.

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

The High Court upheld the decision of the ITAT regarding the...

Court Upholds ITAT Ruling: Unsuitable Comparables Excluded in Engineering Services TNMM Analysis.

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Income Tax December 7, 2024 Case Laws HC
The High Court upheld the decision of the ITAT regarding the selection of comparables for benchmarking analysis under the Transactional Net Margin Method (TNMM). The court concurred that companies like Kitco Ltd., TCE Consulting Engineers Ltd., Project and Development India Ltd., and Mahindra Consulting Engineers Ltd. were not appropriate comparables for the assessee, who was engaged in engineering and design services. Despite the TNMM's tolerance for functional dissimilarities, the comparables' broad functional profiles must be similar. Comparing entities with different functionalities solely based on the TNMM's tolerance would be erroneous. The ITAT's findings aligned with the arm's length principle provisions u/s 92C of the Income Tax Act.
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Acts Income Tax
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