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    August 31, 2026   Case Laws Income Tax
    Crystallised corporate guarantee liability remains deductible in the year of settlement despite later discharge through consent terms.
    August 31, 2026   Case Laws Income Tax
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    August 31, 2026   Case Laws Income Tax
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    August 31, 2026   Case Laws Income Tax
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    Subsequent TDS remittance removes verified principal liability, while delayed-payment interest runs only until the actual deposit date.
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    Year-end estimated provisions do not trigger TDS until an identifiable payee and crystallised liability exist, defeating default demands.
    August 31, 2026   Case Laws Income Tax
    Struck-off company assessments remain valid for tax liabilities, while unexplained-credit disputes require merits adjudication after a hearing.
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    August 31, 2026   Case Laws Customs
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    August 31, 2026   Case Laws IBC
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August 31, 2026   Case Laws Income Tax
Crystallised corporate guarantee liability remains deductible in the year of settlement despite later discharge through consent terms.
August 31, 2026   Case Laws Income Tax
Tax deducted at source can bar delayed-return prosecution where no assessed tax remains payable after statutory adjustments.
August 31, 2026   Case Laws Income Tax
Reassessment notice limitation cannot be extended beyond notification scope, and deemed service cannot cure a time-barred notice.
August 31, 2026   Case Laws Income Tax
Extended search assessment period requires escaped income to be represented by a qualifying asset; unsupported reassessments are invalid.
August 31, 2026   Case Laws Income Tax
Export commission to non-resident agents remains outside Indian tax charge where services are rendered wholly outside India.
August 31, 2026   Case Laws Income Tax
Electronic WhatsApp evidence without authentication or independent corroboration cannot sustain an unexplained-investment addition based on third-party search material.
August 31, 2026   Case Laws Income Tax
Live broadcasting rights: licence fees avoid royalty treatment, while athlete release fees are not taxed as personal activity income.
August 31, 2026   Case Laws Income Tax
Mutual current-account transactions excluded from deemed dividend treatment where no fresh borrowing arose; unsupported unsecured-loan addition also fails.
August 31, 2026   Case Laws Income Tax
Revisionary jurisdiction cannot replace a completed inquiry merely because a broader factual verification is later preferred.
August 31, 2026   Case Laws Income Tax
Subsequent TDS remittance removes verified principal liability, while delayed-payment interest runs only until the actual deposit date.
August 31, 2026   Case Laws Income Tax
Year-end estimated provisions do not trigger TDS until an identifiable payee and crystallised liability exist, defeating default demands.
August 31, 2026   Case Laws Income Tax
Struck-off company assessments remain valid for tax liabilities, while unexplained-credit disputes require merits adjudication after a hearing.
August 31, 2026   Case Laws Income Tax
Deemed dividend requires a genuine shareholder loan or advance; repayment of a company liability falls outside the provision.
August 31, 2026   Case Laws Income Tax
Capital-gains consideration for unquoted share transfers cannot be replaced with a later transaction's value without statutory basis.
August 31, 2026   Case Laws Income Tax
Capital-gains bond exemption applies separate financial-year limits when the six-month investment period spans two years.
August 31, 2026   Case Laws Income Tax
Scheduled Tribe income exemption requires proof of a bona fide source, excluding unexplained cash deposits.
August 31, 2026   Case Laws Customs
Technical expert evidence in customs classification must receive reasoned evaluation; denial of concession was quashed and remanded.
August 31, 2026   Case Laws Customs
Burden of proof for reclassification prevents lead-bearing powder from being treated as lead waste and scrap without conclusive scientific evidence.
August 31, 2026   Case Laws Companies Law
NBFC prudential-norm breaches may support oppression and mismanagement claims when combined with related-party dealings and governance failures.
August 31, 2026   Case Laws IBC
Operational debt from consortium supply advances survives where no genuine pre-existing dispute predates the insolvency demand notice.

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Income Tax

Rejection of a nil/low withholding certificate under s.197 was...

Nil/low withholding certificate u/s197 and dependent agent PE presumption: past-year findings rejected, fresh reconsideration ordered for AY 2025-26

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Income Tax December 26, 2025 Case Laws HC
Rejection of a nil/low withholding certificate under s.197 was challenged on the ground that the AO fixed withholding at 8.75% by presuming a dependent agent PE in India based solely on findings from earlier years. The court held that taxability and PE determination are assessment-year specific, and the ITAT's findings for AYs 2021-22 and 2022-23 that no dependent agent PE existed materially undermined reliance on past assessments for current withholding purposes. As the challenge for AY 2024-25 was withdrawn and there was no demonstrated PE finding for subsequent years, the AO was directed to reconsider the s.197 certificate for AY 2025-26 afresh on that year's facts. - HC
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