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    January 12, 2026   Circulars DGFT
    India-Arab Chamber authorised to issue non-preferential Certificates of Origin for export shipments under Foreign Trade Policy 2023
    January 12, 2026   Circulars DGFT
    eBRC format updated to capture GSTIN and GST invoice details; revised Appendix 2U mandatory for eBRCs from 13 Jan 2026
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    January 12, 2026   Case Laws Income Tax
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    January 12, 2026   Case Laws Income Tax
    Insurer's investment gains and investment write-downs face Section 263 revision; enquiry upheld, Rule 5(b)(ii) lapse sustained, late corrigendum quash...
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    Company investments and subsidies: s14A interest disallowance barred with surplus funds; industrial subsidies treated capital, MAT additions denied
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    Import classification of door locks and other goods-extended limitation u/s28(4) rejected; out-of-jurisdiction duty demands set aside.
    January 12, 2026   Case Laws Customs
    Countervailing duty dispute on imported silk fabrics (2012-13): CVD held not leviable; extended limitation and penalties set aside
    January 12, 2026   Case Laws Customs
    Post-LEO Bills of Lading edits to alter discharge port in drawback exports upheld as misdeclaration; DRI SCNs valid.
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January 12, 2026   Circulars DGFT
India-Arab Chamber authorised to issue non-preferential Certificates of Origin for export shipments under Foreign Trade Policy 2023
January 12, 2026   Circulars DGFT
eBRC format updated to capture GSTIN and GST invoice details; revised Appendix 2U mandatory for eBRCs from 13 Jan 2026
January 12, 2026   Circulars SEBI
AIF investor accreditation delays scheme corpus counting; managers may sign contribution agreements, accept funds only after certificate issued
January 12, 2026   Circulars Customs
Courier transshipment of imported goods via named carrier to air cargo stations renewed until 30.01.2026; exemption conditional, strict controls apply.
January 12, 2026   Circulars Customs
Transshipment of imported courier goods from new terminal to nominated air cargo ports allowed, with bonds and strict procedures
January 12, 2026   Circulars Customs
Five-year renewal of imported cargo custodianship u/s 45(1), with bonds, insurance and strict handling compliance conditions
January 12, 2026   Case Laws Income Tax
Residential status and India-Singapore DTAA tie-breaker for AY 2020-21: s.6(1)(c) thresholds met, resident upheld
January 12, 2026   Case Laws Income Tax
Delay in remitting TDS under s. 276B-maternity leave staff shortage cited as reasonable cause; prosecution quashed, challenge dismissed.
January 12, 2026   Case Laws Income Tax
Cooperative society's delayed tax returns and audit reports due to missing auditors; condonation granted, filings allowed for 80P claims.
January 12, 2026   Case Laws Income Tax
Royalty transfer pricing ALP review: s.263 revision quashed where no s.92CA(3) order existed and TPO time-barred
January 12, 2026   Case Laws Income Tax
Insurer's investment gains and investment write-downs face Section 263 revision; enquiry upheld, Rule 5(b)(ii) lapse sustained, late corrigendum quashed
January 12, 2026   Case Laws Income Tax
Company investments and subsidies: s14A interest disallowance barred with surplus funds; industrial subsidies treated capital, MAT additions denied
January 12, 2026   Case Laws Income Tax
Joint purchase of immovable property with parent: alleged unexplained investment and expenses u/ss69/69C deleted after sources proved.
January 12, 2026   Case Laws Income Tax
Non-resident equity funding into Indian subsidiary recorded in books; s.69 unexplained investment addition to be deleted after verification.
January 12, 2026   Case Laws Income Tax
Non-resident advisory consultancy fees under India-UAE treaty: treated as professional services, not taxable without PE
January 12, 2026   Case Laws Income Tax
Loan credits and transaction discrepancies: reassessment reopening u/s147 and s.68 addition overturned for lack of nexus, evidence proved
January 12, 2026   Case Laws Customs
Voluntary payment of differential customs duty on two import invoices before notice wipes out confiscation and penalties
January 12, 2026   Case Laws Customs
Import classification of door locks and other goods-extended limitation u/s28(4) rejected; out-of-jurisdiction duty demands set aside.
January 12, 2026   Case Laws Customs
Countervailing duty dispute on imported silk fabrics (2012-13): CVD held not leviable; extended limitation and penalties set aside
January 12, 2026   Case Laws Customs
Post-LEO Bills of Lading edits to alter discharge port in drawback exports upheld as misdeclaration; DRI SCNs valid.

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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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