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    August 12, 2026   Case LawsGST
    GST registration cancellation appeals may be restored for merits review where genuine delay explanations justify condonation of limitation.
    August 12, 2026   Case LawsGST
    Fresh GST proceedings after quashed notices remain within limitation, but prejudged show cause notices require neutral reissuance.
    August 12, 2026   Case LawsGST
    Proper officer jurisdiction for a combined GST demand supports one waiver application covering operations across multiple States.
    August 12, 2026   Case LawsGST
    Duplicate GST assessment orders for the same return mismatch cannot coexist; earlier assessment remanded subject to tax payment.
    August 12, 2026   Case LawsGST
    GST amnesty waiver covers self-assessed tax determined under Section 73, while Rule 164 deadlines and approval safeguards remain mandatory.
    August 12, 2026   Case LawsGST
    Distinct legal entity principle bars GST recovery from company bank accounts for deceased proprietor's unpaid dues.
    August 12, 2026   Case LawsGST
    Export turnover mismatches require documentary substantiation and a meaningful opportunity before ex parte GST adjudication is finally sustained.
    August 12, 2026   Case LawsGST
    Communication date for limitation follows the dealer's unrebutted declaration, requiring fresh consideration of the dismissed statutory appeal.
    August 12, 2026   Case LawsIncome Tax
    Mandatory settlement limitation period runs from first Interim Board allotment; administrative transfers cannot revive expired disposal time.
    August 12, 2026   Case LawsIncome Tax
    Identity-theft defences do not bar reassessment, but Revenue must prove disputed transactions through primary evidence during proceedings.
    August 12, 2026   Case LawsIncome Tax
    Discounted Cash Flow valuation for newly incorporated companies was accepted despite later notification under the prescribed valuation rule.
    August 12, 2026   Case LawsIncome Tax
    Internal CUP method upheld for project-office transactions where contract risks, rewards and revenue were fully attributed to India.
    August 12, 2026   Case LawsIncome Tax
    Revisional relief for double taxation requires merits review where the same income is assessed in two different years.
    August 12, 2026   Case LawsIncome Tax
    Charitable registration turns on predominant purpose and genuine activities, while incidental fees and related-party rent require supporting adverse m...
    August 12, 2026   Case LawsIncome Tax
    MAT book-profit adjustments exclude disallowances for exempt-income expenditure and demerger expenditure unless expressly listed under the statutory c...
    August 12, 2026   Case LawsIncome Tax
    CSR donation deductions and treaty-limited dividend tax support relief for eligible contributions and UK shareholder distributions.
    August 12, 2026   Case LawsIncome Tax
    TDS non-deduction under binding interim directions does not make an employer-bank an assessee in default.
    August 12, 2026   Case LawsIncome Tax
    Reassessment based on search and independent enquiry sustained, while unverifiable purchases were limited to the estimated profit element.
    August 12, 2026   Case LawsIncome Tax
    Reasonable cause for cash land-transaction receipts and repayments supported deletion of penalties for statutory cash-payment breaches.
    August 12, 2026   Case LawsIncome Tax
    Specific misreporting charge under section 270A is mandatory; failure to identify the statutory limb invalidates enhanced penalty.
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    August 12, 2026   Case Laws GST
    GST registration cancellation appeals may be restored for merits review where genuine delay explanations justify condonation of limitation.
    August 12, 2026   Case Laws GST
    Fresh GST proceedings after quashed notices remain within limitation, but prejudged show cause notices require neutral reissuance.
    August 12, 2026   Case Laws GST
    Proper officer jurisdiction for a combined GST demand supports one waiver application covering operations across multiple States.
    August 12, 2026   Case Laws GST
    Duplicate GST assessment orders for the same return mismatch cannot coexist; earlier assessment remanded subject to tax payment.
    August 12, 2026   Case Laws GST
    GST amnesty waiver covers self-assessed tax determined under Section 73, while Rule 164 deadlines and approval safeguards remain mandatory.
    August 12, 2026   Case Laws GST
    Distinct legal entity principle bars GST recovery from company bank accounts for deceased proprietor's unpaid dues.
    August 12, 2026   Case Laws GST
    Export turnover mismatches require documentary substantiation and a meaningful opportunity before ex parte GST adjudication is finally sustained.
    August 12, 2026   Case Laws GST
    Communication date for limitation follows the dealer's unrebutted declaration, requiring fresh consideration of the dismissed statutory appeal.
    August 12, 2026   Case Laws Income Tax
    Mandatory settlement limitation period runs from first Interim Board allotment; administrative transfers cannot revive expired disposal time.
    August 12, 2026   Case Laws Income Tax
    Identity-theft defences do not bar reassessment, but Revenue must prove disputed transactions through primary evidence during proceedings.
    August 12, 2026   Case Laws Income Tax
    Discounted Cash Flow valuation for newly incorporated companies was accepted despite later notification under the prescribed valuation rule.
    August 12, 2026   Case Laws Income Tax
    Internal CUP method upheld for project-office transactions where contract risks, rewards and revenue were fully attributed to India.
    August 12, 2026   Case Laws Income Tax
    Revisional relief for double taxation requires merits review where the same income is assessed in two different years.
    August 12, 2026   Case Laws Income Tax
    Charitable registration turns on predominant purpose and genuine activities, while incidental fees and related-party rent require supporting adverse material.
    August 12, 2026   Case Laws Income Tax
    MAT book-profit adjustments exclude disallowances for exempt-income expenditure and demerger expenditure unless expressly listed under the statutory computation rules.
    August 12, 2026   Case Laws Income Tax
    CSR donation deductions and treaty-limited dividend tax support relief for eligible contributions and UK shareholder distributions.
    August 12, 2026   Case Laws Income Tax
    TDS non-deduction under binding interim directions does not make an employer-bank an assessee in default.
    August 12, 2026   Case Laws Income Tax
    Reassessment based on search and independent enquiry sustained, while unverifiable purchases were limited to the estimated profit element.
    August 12, 2026   Case Laws Income Tax
    Reasonable cause for cash land-transaction receipts and repayments supported deletion of penalties for statutory cash-payment breaches.
    August 12, 2026   Case Laws Income Tax
    Specific misreporting charge under section 270A is mandatory; failure to identify the statutory limb invalidates enhanced penalty.

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

      TP adjustment upheld as per Special Bench ruling in...

      TP adjustment upheld; tax treaty benefit denied; mirror ALP rejected; receipts taxable on receipt basis; software, services income non-taxable.

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      Income TaxDecember 26, 2024Case LawsAT
      TP adjustment upheld as per Special Bench ruling in Instrumentarium rejecting base erosion argument. Benefit of tax treaty against TP provisions rejected following earlier ITAT order. Mirror ALP principle rejected relying on Filtrex Technologies. Receipts taxable only on receipt basis per Ampacet Cyprus to be re-adjudicated. Software income treated as non-royalty and Global P&T services, HLPL receipts, L&T services income held as non-fees for technical services deleting respective additions following earlier ITAT orders.
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      ActsIncome Tax
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