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    August 5, 2026   Case LawsIncome Tax
    Website development depreciation, banking gateway fees, and revenue advertising expenses receive favourable treatment under discussed tax principles.
    August 5, 2026   Case LawsIncome Tax
    Foreign-currency loan benchmarking follows the loan currency, while export hedging losses qualify as non-speculative business losses.
    August 5, 2026   Case LawsIncome Tax
    Delayed initiation of TDS return penalties after nine years rendered the penalty illegal and unsustainable.
    August 5, 2026   Case LawsIncome Tax
    Project-development assistance treated as capital, while infrastructure construction costs may be amortised over the concession period.
    August 5, 2026   Case LawsIncome Tax
    Delayed trade receivables require separate transfer pricing benchmarking, subject to debt-free status and an appropriate credit period.
    August 5, 2026   Case LawsIncome Tax
    Modified returns, MAT book profit limits, and tested-party selection shape transfer pricing treatment of integrated intra-group services.
    August 5, 2026   Case LawsIncome Tax
    Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
    August 5, 2026   Case LawsIncome Tax
    Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
    August 5, 2026   Case LawsIncome Tax
    Share valuation method choice protects DCF valuations from replacement with NAV, though projections remain open to scrutiny.
    August 5, 2026   Case LawsIncome Tax
    Penalty immunity requires reconsideration where rectification removes the assessment demand and leaves a refund instead.
    August 5, 2026   Case LawsIncome Tax
    Under-reporting penalty applies when taxable income is not returned, even if reassessment disclosure is accepted without additions.
    August 5, 2026   Case LawsBenami Property
    Benami RTGS credits unsupported by independent evidence justified attachment, while unproven prejudice defeated the natural justice challenge.
    August 5, 2026   Case LawsCustoms
    Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
    August 5, 2026   Case LawsCustoms
    Brand rate drawback for bus bodies may coexist with DEPB where duplicate duty reimbursement is not established by evidence.
    August 5, 2026   Case LawsCustoms
    Made-up textile article classification governs triangular umbrella panels, while full customs disclosure prevents extended limitation in classificatio...
    August 5, 2026   Case LawsCustoms
    Abetment penalties require proof that a Customs Broker representative knowingly facilitated improper importation of prohibited goods.
    August 5, 2026   Case LawsCustoms
    Actual user conditions prohibit disguised sales of duty-free inputs through arrangements labelled as job work.
    August 5, 2026   Case LawsCustoms
    Abetment of attempted export requires proven positive assistance or knowledge; penalties cannot rest on unsupported allegations of concealment.
    August 5, 2026   Case LawsIBC
    Unsubmitted arbitral award claims are extinguished by approved resolution plans, while court-deposited security remains the corporate debtor's asset.
    August 5, 2026   Case LawsIBC
    Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
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    August 5, 2026   Case Laws Income Tax
    Website development depreciation, banking gateway fees, and revenue advertising expenses receive favourable treatment under discussed tax principles.
    August 5, 2026   Case Laws Income Tax
    Foreign-currency loan benchmarking follows the loan currency, while export hedging losses qualify as non-speculative business losses.
    August 5, 2026   Case Laws Income Tax
    Delayed initiation of TDS return penalties after nine years rendered the penalty illegal and unsustainable.
    August 5, 2026   Case Laws Income Tax
    Project-development assistance treated as capital, while infrastructure construction costs may be amortised over the concession period.
    August 5, 2026   Case Laws Income Tax
    Delayed trade receivables require separate transfer pricing benchmarking, subject to debt-free status and an appropriate credit period.
    August 5, 2026   Case Laws Income Tax
    Modified returns, MAT book profit limits, and tested-party selection shape transfer pricing treatment of integrated intra-group services.
    August 5, 2026   Case Laws Income Tax
    Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustments.
    August 5, 2026   Case Laws Income Tax
    Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments cannot survive statutory omission.
    August 5, 2026   Case Laws Income Tax
    Share valuation method choice protects DCF valuations from replacement with NAV, though projections remain open to scrutiny.
    August 5, 2026   Case Laws Income Tax
    Penalty immunity requires reconsideration where rectification removes the assessment demand and leaves a refund instead.
    August 5, 2026   Case Laws Income Tax
    Under-reporting penalty applies when taxable income is not returned, even if reassessment disclosure is accepted without additions.
    August 5, 2026   Case Laws Benami Property
    Benami RTGS credits unsupported by independent evidence justified attachment, while unproven prejudice defeated the natural justice challenge.
    August 5, 2026   Case Laws Customs
    Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation right.
    August 5, 2026   Case Laws Customs
    Brand rate drawback for bus bodies may coexist with DEPB where duplicate duty reimbursement is not established by evidence.
    August 5, 2026   Case Laws Customs
    Made-up textile article classification governs triangular umbrella panels, while full customs disclosure prevents extended limitation in classification disputes.
    August 5, 2026   Case Laws Customs
    Abetment penalties require proof that a Customs Broker representative knowingly facilitated improper importation of prohibited goods.
    August 5, 2026   Case Laws Customs
    Actual user conditions prohibit disguised sales of duty-free inputs through arrangements labelled as job work.
    August 5, 2026   Case Laws Customs
    Abetment of attempted export requires proven positive assistance or knowledge; penalties cannot rest on unsupported allegations of concealment.
    August 5, 2026   Case Laws IBC
    Unsubmitted arbitral award claims are extinguished by approved resolution plans, while court-deposited security remains the corporate debtor's asset.
    August 5, 2026   Case Laws IBC
    Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration.

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

      ITAT upheld characterization of outstanding dues beyond agreed...

      Intra-group receivables beyond credit period recharacterized as financing, interest adjustment upheld.

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      Income TaxDecember 27, 2024Case LawsAT
      ITAT upheld characterization of outstanding dues beyond agreed credit period as separate international transaction of providing finance, requiring separate benchmarking. Interest adjustment limited to financial year under consideration. RBI COVID-19 relaxations not applicable to relevant period. No recharacterization of transaction by TPO. Commercial expediency for delayed receivables not established. Netting of receivables/payables permitted if demonstrated. Lack of show cause notice not fatal. Working capital adjustment to be considered for removing interest adjustment. MAT book profit computation remitted for rectification. Directed to grant tax credits after verification.
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      ActsIncome Tax
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