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    January 19, 2026   Case Laws Benami Property
    Provisional attachment under Benami Transactions Act lacked independent evidence and was set aside for insufficient proof.
    January 19, 2026   Case Laws Customs
    Woven synthetic filament yarn fabrics found eligible for FPS duty credit; DGFT circular cannot narrow Appendix 37D entitlement
    January 19, 2026   Case Laws Customs
    Dark seedless raisins: classified under CTI 08062010; exemption only if Vitis vinifera origin proven by PQ/FSSAI and port check
    January 19, 2026   Case Laws Customs
    Imported multi-functional electrical distribution racks, despite UPS ancillary, classed under 8537 10 90, entitled to concessional BCD
    January 19, 2026   Case Laws Customs
    Portable mobile, tablet, wearable and vehicle computers classified as portable ADP machines; ruled under tariff subheading 8471.30 84713090
    January 19, 2026   Case Laws IBC
    Admission into CIRP based on existence of financial debt and default; homebuyers' society denied locus to intervene or appeal
    January 19, 2026   Case Laws Money Laundering
    Property acquired before predicate offence treated as "proceeds of crime" u/s2(1)(u); provisional attachment upheld
    January 19, 2026   Case Laws Money Laundering
    Cash routed to non-existent firm deemed proceeds of crime; laundered funds and properties attachable, provisional attachments confirmed; two accounts ...
    January 19, 2026   Case Laws Service Tax
    Continuation of Section 73 service-tax proceedings after provider's death (construing s.65(7)) - held to abate; posthumous OIO and recoveries invalida...
    January 19, 2026   Case Laws Central Excise
    Whether fly ash is excisable and duty paid under protest refundable; tribunal allowed refund, set aside order (Section 11B)
    January 17, 2026   Case Laws GST
    ISD distribution monthly time-limit u/r 39(1)(a) found to exceed delegated power, extinguish ITC; audit quashed
    January 17, 2026   Case Laws GST
    Classification of repackaged rice-bran oil sold as lamp oil under competing tariff headings; writ dismissed, appeal allowed within 30 days
    January 17, 2026   Case Laws GST
    Failure to pass Input Tax Credit to home buyers results in order to remit Rs.3.12 crore plus interest and file compliance report
    January 17, 2026   Case Laws Income Tax
    Capital gains taxability of shares held by Mauritius companies clarified; transfers after 01.04.2017 taxable and Chapter X-A applies
    January 17, 2026   Case Laws Income Tax
    Jurisdictional Assessing Officer initiating Section 148A/148 assessments after Faceless Scheme held ultra vires; notices quashed
    January 17, 2026   Case Laws Income Tax
    Survey-found employee list income extrapolation disallowed; addition limited to Rs.2,54,115 taxed u/s69C read with s.115BBE
    January 17, 2026   Case Laws Income Tax
    Bright Line Test for AMP expense allocation rejected as transfer-pricing benchmark; AMP adjustment deleted on appeal
    January 17, 2026   Case Laws Income Tax
    Digital images' admissibility as electronic evidence rejected for lack of s.65B compliance, chain of custody, and hash linkage
    January 17, 2026   Case Laws Income Tax
    Cash advances treated as project receipts taxed on project completion, appeal allowed; other additions and interest disallowed, s.22 rent sustained
    January 17, 2026   Case Laws Income Tax
    Captive solar power generation serving corporate shareholder lacks public character under predominant-object test; 12AB/80G registration refused (15)
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January 19, 2026   Case Laws Benami Property
Provisional attachment under Benami Transactions Act lacked independent evidence and was set aside for insufficient proof.
January 19, 2026   Case Laws Customs
Woven synthetic filament yarn fabrics found eligible for FPS duty credit; DGFT circular cannot narrow Appendix 37D entitlement
January 19, 2026   Case Laws Customs
Dark seedless raisins: classified under CTI 08062010; exemption only if Vitis vinifera origin proven by PQ/FSSAI and port check
January 19, 2026   Case Laws Customs
Imported multi-functional electrical distribution racks, despite UPS ancillary, classed under 8537 10 90, entitled to concessional BCD
January 19, 2026   Case Laws Customs
Portable mobile, tablet, wearable and vehicle computers classified as portable ADP machines; ruled under tariff subheading 8471.30 84713090
January 19, 2026   Case Laws IBC
Admission into CIRP based on existence of financial debt and default; homebuyers' society denied locus to intervene or appeal
January 19, 2026   Case Laws Money Laundering
Property acquired before predicate offence treated as "proceeds of crime" u/s2(1)(u); provisional attachment upheld
January 19, 2026   Case Laws Money Laundering
Cash routed to non-existent firm deemed proceeds of crime; laundered funds and properties attachable, provisional attachments confirmed; two accounts released.
January 19, 2026   Case Laws Service Tax
Continuation of Section 73 service-tax proceedings after provider's death (construing s.65(7)) - held to abate; posthumous OIO and recoveries invalidated
January 19, 2026   Case Laws Central Excise
Whether fly ash is excisable and duty paid under protest refundable; tribunal allowed refund, set aside order (Section 11B)
January 17, 2026   Case Laws GST
ISD distribution monthly time-limit u/r 39(1)(a) found to exceed delegated power, extinguish ITC; audit quashed
January 17, 2026   Case Laws GST
Classification of repackaged rice-bran oil sold as lamp oil under competing tariff headings; writ dismissed, appeal allowed within 30 days
January 17, 2026   Case Laws GST
Failure to pass Input Tax Credit to home buyers results in order to remit Rs.3.12 crore plus interest and file compliance report
January 17, 2026   Case Laws Income Tax
Capital gains taxability of shares held by Mauritius companies clarified; transfers after 01.04.2017 taxable and Chapter X-A applies
January 17, 2026   Case Laws Income Tax
Jurisdictional Assessing Officer initiating Section 148A/148 assessments after Faceless Scheme held ultra vires; notices quashed
January 17, 2026   Case Laws Income Tax
Survey-found employee list income extrapolation disallowed; addition limited to Rs.2,54,115 taxed u/s69C read with s.115BBE
January 17, 2026   Case Laws Income Tax
Bright Line Test for AMP expense allocation rejected as transfer-pricing benchmark; AMP adjustment deleted on appeal
January 17, 2026   Case Laws Income Tax
Digital images' admissibility as electronic evidence rejected for lack of s.65B compliance, chain of custody, and hash linkage
January 17, 2026   Case Laws Income Tax
Cash advances treated as project receipts taxed on project completion, appeal allowed; other additions and interest disallowed, s.22 rent sustained
January 17, 2026   Case Laws Income Tax
Captive solar power generation serving corporate shareholder lacks public character under predominant-object test; 12AB/80G registration refused (15)

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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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