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    January 23, 2026   Case Laws GST
    Profiteering in real estate GST input tax credit passthrough found; developer to refund Rs 1.00 crore plus interest to buyers.
    January 23, 2026   Case Laws Income Tax
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    Freight payment compliance and unrecorded cash evidence in tax assessment reviewed; additions deleted for lack of corroboration and verification
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    TDS obligations on rental and legal fees: liability upheld for non-deduction on provisions, partial relief where TDS paid on actual payment.
    January 23, 2026   Case Laws Income Tax
    Jurisdiction to transfer under section 127 invalidates orders by non-jurisdictional AO, assessment orders quashed by ITAT
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    Levy of service tax on penal interest, notice pay and CSR sponsorship examined; sponsorship demands and penalties sustained in part.
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    Minimum Import Price restrictions for Black Pepper, Areca-nuts and Apples upheld; procedural laying failure not fatal, notifications to be placed befo...
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    January 23, 2026   Case Laws Customs
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    January 23, 2026   Case Laws Customs
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    January 23, 2026   Case Laws Customs
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January 23, 2026   Case Laws GST
Profiteering in real estate GST input tax credit passthrough found; developer to refund Rs 1.00 crore plus interest to buyers.
January 23, 2026   Case Laws Income Tax
TDS credit denial and territorial jurisdiction in income-tax intimation: credit restored and refund with interest directed.
January 23, 2026   Case Laws Income Tax
Certificate under Section 197 tax deduction at source: power of attorney does not establish residency, order quashed.
January 23, 2026   Case Laws Income Tax
Reopening of income-tax assessment after search: computation of six-year and ten-year limitation periods renders older notice barred and quashed.
January 23, 2026   Case Laws Income Tax
International transaction characterisation of domestic divestment of support services business rejected; transaction between resident associated enterprises not deemed international, appeal allowed
January 23, 2026   Case Laws Income Tax
Freight payment compliance and unrecorded cash evidence in tax assessment reviewed; additions deleted for lack of corroboration and verification
January 23, 2026   Case Laws Income Tax
TDS obligations on rental and legal fees: liability upheld for non-deduction on provisions, partial relief where TDS paid on actual payment.
January 23, 2026   Case Laws Income Tax
Jurisdiction to transfer under section 127 invalidates orders by non-jurisdictional AO, assessment orders quashed by ITAT
January 23, 2026   Case Laws Income Tax
Penalty under section 271AAA on disclosure during search: relief granted where income was disclosed, explained and taxes paid
January 23, 2026   Case Laws Income Tax
Valuation of share premium and applicability to non-resident subscribers: rectification extinguishes addition and addition deleted on merits
January 23, 2026   Case Laws Income Tax
Assessment order in name of deceased assessee treated as irregular, rectifiable by bringing legal heirs on record under succession provisions
January 23, 2026   Case Laws Service Tax
Levy of service tax on penal interest, notice pay and CSR sponsorship examined; sponsorship demands and penalties sustained in part.
January 23, 2026   Case Laws Customs
Minimum Import Price restrictions for Black Pepper, Areca-nuts and Apples upheld; procedural laying failure not fatal, notifications to be placed before Parliament
January 23, 2026   Case Laws Customs
Transaction value between related persons requires market-equivalent pricing; importer must prove declared value mirrors ordinary international trade price.
January 23, 2026   Case Laws Customs
Classification of imported aluminium tubes, pipes and profiles: held under specific tariff headings, exemption granted and penalties quashed
January 23, 2026   Case Laws Customs
Imported food consignment cleared despite a rejection test report; confiscation and penalties set aside due to procedural lapses
January 23, 2026   Case Laws Customs
Classification of exported insecticides under export tariff affirmed; reclassification and related penalties set aside and MEIS scrip jurisdiction recognised
January 23, 2026   Case Laws Customs
Imports under Advance Authorisation challenged for pre-import condition failure; tribunal rejects revenues proof and quashes IGST penalties.
January 23, 2026   Case Laws Customs
Admissibility of computer printouts and statements under section 108 in customs valuation; reassessment and penalties set aside.
January 23, 2026   Case Laws Customs
Retroactive application of amended Explanation 4 to Section 28 bars adjudication of pre-amendment show cause notices, leading to vacatur.

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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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