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    January 7, 2026   Case Laws Income Tax
    Bank's tax computation: no s.14A Rule 8D on stock-in-trade shares; foreign tax credit verification ordered; MAT s.115JB inapplicable.
    January 7, 2026   Case Laws Income Tax
    Business loss, ESOP cross-charge and manpower reimbursements: deductions allowed; s.195 TDS not required on parent ESOP cost reimbursement
    January 7, 2026   Case Laws Income Tax
    Land-trading search disclosure and alleged on-money plot sales: s68/115BBE cash-credit and loose-paper additions largely deleted, telescoping verified
    January 7, 2026   Case Laws Income Tax
    Land-sale capital gains: whether land was urban within municipal limits u/s2(14); s.263 revision upheld for no inquiry
    January 7, 2026   Case Laws Income Tax
    Expense claims disallowance estimated at 20% triggers s.270A penalty dispute; penalty quashed for lack of satisfaction
    January 7, 2026   Case Laws Income Tax
    Tax reassessment after case transfer without written s.127 order: transferee officer lacked jurisdiction; ss.147/143(3) order quashed.
    January 7, 2026   Case Laws Customs
    Export bill discounting under Interest Equalisation Scheme: bank barred from clawing back 5% interest subvention after 30 Sept 2021
    January 7, 2026   Case Laws Customs
    Imported network interface cards and communication modules: CTI 8517 70 90 parts vs 8517 62 90 machines; demand time-barred
    January 7, 2026   Case Laws Customs
    Export consignment diversion to misuse Focus Market Scheme benefits-statements u/s108 ruled inadmissible; confiscation and penalties set aside.
    January 7, 2026   Case Laws Companies Law
    Interim forensic audit in company oppression/mismanagement dispute under ss 241-242 upheld despite no specific audit request; appeal dismissed
    January 7, 2026   Case Laws IBC
    Corporate debtor resolution plan and "unsustainable debt": third-party promoter/surety security liability continues; creditor rights preserved, appeal...
    January 7, 2026   Case Laws IBC
    Pre-CIRP asset sale alleged without consideration to defraud creditors; intent not proved, liquidator's avoidance appeal dismissed
    January 7, 2026   Case Laws IBC
    Operational creditor disputes CIRP resolution plan payouts versus liquidation value, but collateral challenge barred; plan approval stands dismissed.
    January 7, 2026   Case Laws IBC
    Operational debt payment dispute recorded in information utility leads to rejection of Section 9 IBC insolvency application under 9(5)(ii)(d)
    January 7, 2026   Case Laws IBC
    Operational debt claim under leave-and-licence agreement: double licence fee, amenities disputes, and termination impact; Section 9 order remanded
    January 7, 2026   Case Laws IBC
    Stakeholder's failure to remit CIRP costs on time led to compliance order with contempt warning; appeal dismissed
    January 7, 2026   Case Laws IBC
    Auction sale of corporate debtor's attached yacht before CIRP: s14 IBC moratorium held inapplicable, set-aside order reversed
    January 7, 2026   Case Laws IBC
    Mortgaged land survey and boundary demarcation after liquidation sale certificate, purchaser's plea for repeat survey rejected
    January 7, 2026   Case Laws Money Laundering
    Alleged laundering of diverted public bank funds through layering, accused as beneficiary; regular bail granted amid trial delay
    January 7, 2026   Case Laws Money Laundering
    IBC resolution plan immunity from money-laundering: corporate debtor removed as accused; cases continue against ex-directors, attached assets refunded...
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January 7, 2026   Case Laws Income Tax
Bank's tax computation: no s.14A Rule 8D on stock-in-trade shares; foreign tax credit verification ordered; MAT s.115JB inapplicable.
January 7, 2026   Case Laws Income Tax
Business loss, ESOP cross-charge and manpower reimbursements: deductions allowed; s.195 TDS not required on parent ESOP cost reimbursement
January 7, 2026   Case Laws Income Tax
Land-trading search disclosure and alleged on-money plot sales: s68/115BBE cash-credit and loose-paper additions largely deleted, telescoping verified
January 7, 2026   Case Laws Income Tax
Land-sale capital gains: whether land was urban within municipal limits u/s2(14); s.263 revision upheld for no inquiry
January 7, 2026   Case Laws Income Tax
Expense claims disallowance estimated at 20% triggers s.270A penalty dispute; penalty quashed for lack of satisfaction
January 7, 2026   Case Laws Income Tax
Tax reassessment after case transfer without written s.127 order: transferee officer lacked jurisdiction; ss.147/143(3) order quashed.
January 7, 2026   Case Laws Customs
Export bill discounting under Interest Equalisation Scheme: bank barred from clawing back 5% interest subvention after 30 Sept 2021
January 7, 2026   Case Laws Customs
Imported network interface cards and communication modules: CTI 8517 70 90 parts vs 8517 62 90 machines; demand time-barred
January 7, 2026   Case Laws Customs
Export consignment diversion to misuse Focus Market Scheme benefits-statements u/s108 ruled inadmissible; confiscation and penalties set aside.
January 7, 2026   Case Laws Companies Law
Interim forensic audit in company oppression/mismanagement dispute under ss 241-242 upheld despite no specific audit request; appeal dismissed
January 7, 2026   Case Laws IBC
Corporate debtor resolution plan and "unsustainable debt": third-party promoter/surety security liability continues; creditor rights preserved, appeal dismissed
January 7, 2026   Case Laws IBC
Pre-CIRP asset sale alleged without consideration to defraud creditors; intent not proved, liquidator's avoidance appeal dismissed
January 7, 2026   Case Laws IBC
Operational creditor disputes CIRP resolution plan payouts versus liquidation value, but collateral challenge barred; plan approval stands dismissed.
January 7, 2026   Case Laws IBC
Operational debt payment dispute recorded in information utility leads to rejection of Section 9 IBC insolvency application under 9(5)(ii)(d)
January 7, 2026   Case Laws IBC
Operational debt claim under leave-and-licence agreement: double licence fee, amenities disputes, and termination impact; Section 9 order remanded
January 7, 2026   Case Laws IBC
Stakeholder's failure to remit CIRP costs on time led to compliance order with contempt warning; appeal dismissed
January 7, 2026   Case Laws IBC
Auction sale of corporate debtor's attached yacht before CIRP: s14 IBC moratorium held inapplicable, set-aside order reversed
January 7, 2026   Case Laws IBC
Mortgaged land survey and boundary demarcation after liquidation sale certificate, purchaser's plea for repeat survey rejected
January 7, 2026   Case Laws Money Laundering
Alleged laundering of diverted public bank funds through layering, accused as beneficiary; regular bail granted amid trial delay
January 7, 2026   Case Laws Money Laundering
IBC resolution plan immunity from money-laundering: corporate debtor removed as accused; cases continue against ex-directors, attached assets refunded.

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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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