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    August 29, 2026   Case Laws Income Tax
    Share-capital issue expenses include Registrar fees, allowing preliminary-expenditure amortisation where shares are issued to a holding company.
    August 29, 2026   Case Laws Income Tax
    Decoding seized numerical entries requires reasoned evidentiary support; unsupported multipliers fail, while duplicate taxation and financial incapaci...
    August 29, 2026   Case Laws Income Tax
    Revisionary jurisdiction cannot replace an Assessing Officer's considered view after full disclosure and examination during assessment.
    August 29, 2026   Case Laws Income Tax
    Revision for alleged lack of inquiry fails where assessment records show inquiries, application of mind, and no identified defects.
    August 29, 2026   Case Laws Income Tax
    Interest on excess self-assessment tax refunds runs from payment where appellate relief reduces tax ultimately chargeable.
    August 29, 2026   Case Laws Income Tax
    Advance-tax appeal admission requires examination of claimed absence of taxable income before dismissal or remand
    August 29, 2026   Case Laws Income Tax
    Tax-motivated capital loss remains allowable where share transactions are genuine and lack evidence of an artificial arrangement.
    August 29, 2026   Case Laws Income Tax
    Transfer-pricing rules cannot benchmark independently agreed royalty payments without evidence of an associated-enterprise relationship, requiring del...
    August 29, 2026   Case Laws Income Tax
    Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
    August 29, 2026   Case Laws Income Tax
    Cost-to-cost reimbursements exclude value-free third-party expenses from transfer-pricing adjustment, while unsupported salary cross-charges remain ad...
    August 29, 2026   Case Laws Income Tax
    DRP directions bind assessment proceedings, barring protective AMP adjustments and methodology changes through rectification in transfer-pricing asses...
    August 29, 2026   Case Laws Income Tax
    Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
    August 29, 2026   Case Laws Income Tax
    TDS-default expenditure requires proof of prior-year disallowance; unnotified entities cannot claim exemption despite pending writ proceedings.
    August 29, 2026   Case Laws Income Tax
    Double addition of goodwill cannot stand where its book write-off was already added back; depreciation disallowance remained.
    August 29, 2026   Case Laws Income Tax
    Search-related assessment framework governs post-search proceedings, while evidentiary burdens shape loan, cash, and transfer-pricing adjustments.
    August 29, 2026   Case Laws Income Tax
    Trade discount characterisation prevails over tax statement labels when invoice reconciliation establishes the receipts' true nature.
    August 29, 2026   Case Laws Income Tax
    Interest on enhanced compensation remains taxable, while the statutory half deduction must reduce taxable income.
    August 29, 2026   Case Laws Customs
    Reasonable Time for Drawback Recovery invalidates delayed recovery and bank-account attachment where fraud or suppression is not alleged.
    August 29, 2026   Case Laws Customs
    Customs reclassification requires technical evidence; unsupported rejection of mixed-fibre fabric classification cannot sustain duty, interest or pena...
    August 29, 2026   Case Laws Companies Law
    Territorial jurisdiction under Article 226(2) requires substantial nexus and forum convenience, directing the investigation challenge to Mumbai.
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August 29, 2026   Case Laws Income Tax
Share-capital issue expenses include Registrar fees, allowing preliminary-expenditure amortisation where shares are issued to a holding company.
August 29, 2026   Case Laws Income Tax
Decoding seized numerical entries requires reasoned evidentiary support; unsupported multipliers fail, while duplicate taxation and financial incapacity defeat additions.
August 29, 2026   Case Laws Income Tax
Revisionary jurisdiction cannot replace an Assessing Officer's considered view after full disclosure and examination during assessment.
August 29, 2026   Case Laws Income Tax
Revision for alleged lack of inquiry fails where assessment records show inquiries, application of mind, and no identified defects.
August 29, 2026   Case Laws Income Tax
Interest on excess self-assessment tax refunds runs from payment where appellate relief reduces tax ultimately chargeable.
August 29, 2026   Case Laws Income Tax
Advance-tax appeal admission requires examination of claimed absence of taxable income before dismissal or remand
August 29, 2026   Case Laws Income Tax
Tax-motivated capital loss remains allowable where share transactions are genuine and lack evidence of an artificial arrangement.
August 29, 2026   Case Laws Income Tax
Transfer-pricing rules cannot benchmark independently agreed royalty payments without evidence of an associated-enterprise relationship, requiring deletion of disallowance.
August 29, 2026   Case Laws Income Tax
Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental data.
August 29, 2026   Case Laws Income Tax
Cost-to-cost reimbursements exclude value-free third-party expenses from transfer-pricing adjustment, while unsupported salary cross-charges remain adjusted.
August 29, 2026   Case Laws Income Tax
DRP directions bind assessment proceedings, barring protective AMP adjustments and methodology changes through rectification in transfer-pricing assessments.
August 29, 2026   Case Laws Income Tax
Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and margin issues.
August 29, 2026   Case Laws Income Tax
TDS-default expenditure requires proof of prior-year disallowance; unnotified entities cannot claim exemption despite pending writ proceedings.
August 29, 2026   Case Laws Income Tax
Double addition of goodwill cannot stand where its book write-off was already added back; depreciation disallowance remained.
August 29, 2026   Case Laws Income Tax
Search-related assessment framework governs post-search proceedings, while evidentiary burdens shape loan, cash, and transfer-pricing adjustments.
August 29, 2026   Case Laws Income Tax
Trade discount characterisation prevails over tax statement labels when invoice reconciliation establishes the receipts' true nature.
August 29, 2026   Case Laws Income Tax
Interest on enhanced compensation remains taxable, while the statutory half deduction must reduce taxable income.
August 29, 2026   Case Laws Customs
Reasonable Time for Drawback Recovery invalidates delayed recovery and bank-account attachment where fraud or suppression is not alleged.
August 29, 2026   Case Laws Customs
Customs reclassification requires technical evidence; unsupported rejection of mixed-fibre fabric classification cannot sustain duty, interest or penalties.
August 29, 2026   Case Laws Companies Law
Territorial jurisdiction under Article 226(2) requires substantial nexus and forum convenience, directing the investigation challenge to Mumbai.

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Home › Highlights › Income Tax › 2025 › January, 2025 › This
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Income Tax

Appellant, a UK company, had a business connection and PE in...

UK company found to have permanent establishment in India; 15% booking fees taxable.

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Income Tax January 16, 2025 Case Laws AT
Appellant, a UK company, had a business connection and PE in India u/s 9(1). 15% of booking fees were attributable to the PE in India, following earlier decisions for AY 2018-19 and 2019-20. Observations regarding appellant's status as a conduit entity were unnecessary and irrelevant. ITAT allowed appellant's appeal.
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Acts Income Tax
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