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    September 3, 2026   Case Laws GST
    Input tax credit fraud permits Section 74 recovery where invoices and payments do not prove receipt of goods.
    September 3, 2026   Case Laws Money Laundering
    PMLA anticipatory bail requires satisfaction of twin conditions, while predicate-offence protection does not extend to independent money-laundering pr...
    September 3, 2026   Notifications Customs
    Sea cargo manifest compliance date is substituted in the Form XII table, effective upon Official Gazette publication.
    September 3, 2026   Circulars DGFT
    Raw sugar tariff-rate quota allocations move to daily batch processing, with pro-rata sharing when remaining quota is exhausted.
    September 3, 2026   Circulars Customs
    Sea cargo manifest electronic filing becomes mandatory through phased port implementation, with no penalties during the transition period.
    September 3, 2026   Circulars GST
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    September 3, 2026   Case Laws GST
    Security-based bail conditions for alleged tax liabilities were modified when disclosed family assets could secure the alleged dues.
    September 3, 2026   Case Laws GST
    Reasonable cause protects service-tax defaulters from Section 78 penalties when departmental guidance creates genuine interpretational uncertainty.
    September 3, 2026   Case Laws GST
    GST refund restriction omission applies to pending proceedings, requiring related notices, orders and refund claims to be processed accordingly.
    September 3, 2026   Case Laws GST
    Input tax credit for leased construction requires binding precedent consideration; unlawful ledger recovery must be reversed.
    September 3, 2026   Case Laws GST
    Retrospective input tax credit protection overrides delayed-return limits, requiring reconsideration where statutory eligibility under Section 16(5) i...
    September 3, 2026   Case Laws GST
    Electronic gift vouchers can validly pass GST rate-reduction benefits when unconditional, traceable e-wallet credits reach identified customers.
    September 3, 2026   Case Laws GST
    School-affiliation charges remain taxable where not directly connected with examinations, while extended limitation requires proof of deliberate tax e...
    September 3, 2026   Case Laws Income Tax
    Finality of tax liability required before criminal prosecution may be closed; premature closure was set aside for reconsideration.
    September 3, 2026   Case Laws Income Tax
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    September 3, 2026   Case Laws Income Tax
    Abandoned expansion project costs qualify as revenue expenditure when no new enduring asset or distinct business emerges
    September 3, 2026   Case Laws Income Tax
    Share buy-backs with mandatory extinguishment do not create taxable property, while own-funds and lending-business tests support deductions.
    September 3, 2026   Case Laws Income Tax
    Representative capacity under section 194H determines whether an online ticketing platform's retained convenience fee attracts tax deduction at source...
    September 3, 2026   Case Laws Income Tax
    Diamond grading reports do not constitute technical service fees where no technical knowledge or skill is made available.
    September 3, 2026   Case Laws Income Tax
    Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
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September 3, 2026   Case Laws GST
Input tax credit fraud permits Section 74 recovery where invoices and payments do not prove receipt of goods.
September 3, 2026   Case Laws Money Laundering
PMLA anticipatory bail requires satisfaction of twin conditions, while predicate-offence protection does not extend to independent money-laundering proceedings.
September 3, 2026   Notifications Customs
Sea cargo manifest compliance date is substituted in the Form XII table, effective upon Official Gazette publication.
September 3, 2026   Circulars DGFT
Raw sugar tariff-rate quota allocations move to daily batch processing, with pro-rata sharing when remaining quota is exhausted.
September 3, 2026   Circulars Customs
Sea cargo manifest electronic filing becomes mandatory through phased port implementation, with no penalties during the transition period.
September 3, 2026   Circulars GST
Omission of GST refund restriction rule ends its application to proceedings pending on its omission date.
September 3, 2026   Case Laws GST
Security-based bail conditions for alleged tax liabilities were modified when disclosed family assets could secure the alleged dues.
September 3, 2026   Case Laws GST
Reasonable cause protects service-tax defaulters from Section 78 penalties when departmental guidance creates genuine interpretational uncertainty.
September 3, 2026   Case Laws GST
GST refund restriction omission applies to pending proceedings, requiring related notices, orders and refund claims to be processed accordingly.
September 3, 2026   Case Laws GST
Input tax credit for leased construction requires binding precedent consideration; unlawful ledger recovery must be reversed.
September 3, 2026   Case Laws GST
Retrospective input tax credit protection overrides delayed-return limits, requiring reconsideration where statutory eligibility under Section 16(5) is met.
September 3, 2026   Case Laws GST
Electronic gift vouchers can validly pass GST rate-reduction benefits when unconditional, traceable e-wallet credits reach identified customers.
September 3, 2026   Case Laws GST
School-affiliation charges remain taxable where not directly connected with examinations, while extended limitation requires proof of deliberate tax evasion.
September 3, 2026   Case Laws Income Tax
Finality of tax liability required before criminal prosecution may be closed; premature closure was set aside for reconsideration.
September 3, 2026   Case Laws Income Tax
Cash-basis deduction permits Work Contract Tax paid in the relevant year despite liability relating to earlier years.
September 3, 2026   Case Laws Income Tax
Abandoned expansion project costs qualify as revenue expenditure when no new enduring asset or distinct business emerges
September 3, 2026   Case Laws Income Tax
Share buy-backs with mandatory extinguishment do not create taxable property, while own-funds and lending-business tests support deductions.
September 3, 2026   Case Laws Income Tax
Representative capacity under section 194H determines whether an online ticketing platform's retained convenience fee attracts tax deduction at source.
September 3, 2026   Case Laws Income Tax
Diamond grading reports do not constitute technical service fees where no technical knowledge or skill is made available.
September 3, 2026   Case Laws Income Tax
Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from original return.

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

ITAT partly allowed revenue's and assessee's appeals in a TP...

ITAT tweaks TP comparables, retains arm's length margin in EDS, remands software segment ALP u/s 92C

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Income Tax December 9, 2025 Case Laws AT
ITAT partly allowed revenue's and assessee's appeals in a TP dispute concerning software development and EDS segments. Inclusion of CADSYS (India) Pvt. Ltd. was permitted; however, even with this comparable, assessee's margin remained within arm's length, rendering EDS-related grounds academic and dismissed. For the software development segment, ITAT directed exclusion of Infosys Ltd. on turnover filter, upheld exclusion of Three Sixty Logica Testing Services Pvt. Ltd., Indianic Infotech Ltd., Nihilent Ltd., and Cybage Software Pvt. Ltd. from comparables, and remanded the issue of Evoke Technologies Ltd. to AO/TPO for reconsideration. AO/TPO was directed to recompute ALP in accordance with these findings.
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Acts Income Tax
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