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    January 13, 2026   Case Laws Income Tax
    Reopening income-tax assessment u/s 147/148/148A requires tangible material and nexus; notices for AY2019-20 set aside
    January 13, 2026   Case Laws Income Tax
    Victim's right to appeal u/s 372 CrPC affirmed; leave petitions treated as appeals, ruling given retrospective effect
    January 13, 2026   Case Laws Income Tax
    Special-audit approval u/s 142(2A) lacked DIN and justification per Circular No.19/2019, held invalid; audit quashed for assessee
    January 13, 2026   Case Laws Income Tax
    Delay in filing Form No.10-IC to claim Section 115BAA concessional tax-condoned u/s 119(2)(b) after hardship shown
    January 13, 2026   Case Laws Income Tax
    Capital gains tax rate u/s 50/112 must follow binding ITAT Special Bench ruling; order set aside and remanded
    January 13, 2026   Case Laws Income Tax
    Validity of unsigned Section 148 notice declared void; reassessment proceedings based on it held invalid, relief for assessee
    January 13, 2026   Case Laws Income Tax
    Penalty orders u/s 271E/271D-whether limitation u/s 275(1)(c) runs from Assessing Officer's reference; therefore orders time-barred
    January 13, 2026   Case Laws Income Tax
    Seized incriminating documents and receipts determining tax additions for student fees, property investment, and stamp duty - partly upheld
    January 13, 2026   Case Laws Income Tax
    Residential status u/s 6(1) Explanation 1(b): stays below 182 days for 2017-20, s.115C Explanation (e) confirms non-resident
    January 13, 2026   Case Laws Income Tax
    Assessment time-barred u/s 153 due to missing competent-authority reference for Singapore exchange of information; assessment disallowed as barred by ...
    January 13, 2026   Case Laws Income Tax
    Filing wrong ITR form (ITR-7 vs ITR-5) and disallowance of lawful business expenses; tribunal restores deductions, orders refiling and reassessment
    January 13, 2026   Case Laws Income Tax
    AMP payments and marketing salaries via credit-notes found genuine; disallowances deleted; no AMP reallocation; 14A limited
    January 13, 2026   Case Laws Income Tax
    Proprietary software held by taxpayer treated as intangible asset eligible for 60% depreciation allowance, overturning 25% limit
    January 13, 2026   Case Laws Income Tax
    Claiming new tax regime after late Form 10-IE and delayed return: new-regime election infirm; verification ordered and relief possible.
    January 13, 2026   Case Laws Customs
    Imported menthol-scented sweet supari classification dispute: seizure quashed, release for home consumption subject to duty bond; bank guarantee refus...
    January 13, 2026   Case Laws Customs
    Imported fabric thickness discrepancy valuation fixed by contemporaneous imports at US$1.80/m, duties and penalties upheld.
    January 13, 2026   Case Laws Customs
    Classification of product as organic surface-active agent (surfactant) under CTH 3402; held classifiable at CTH 3402 4200 pending import verification
    January 13, 2026   Case Laws Service Tax
    Reimbursements to foreign representative office treated as mere expense recovery, not taxable consideration under reverse-charge; order set aside
    January 13, 2026   Case Laws Service Tax
    Appellants' receipts characterized as taxable services u/s 65B; liability sustained, one receipt exempted; extended limitation not invoked
    January 13, 2026   Case Laws Customs
    CKD/SKD air-conditioner components classifiable with finished units by essential character; prior advance ruling extended three years, FTA benefits po...
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January 13, 2026   Case Laws Income Tax
Reopening income-tax assessment u/s 147/148/148A requires tangible material and nexus; notices for AY2019-20 set aside
January 13, 2026   Case Laws Income Tax
Victim's right to appeal u/s 372 CrPC affirmed; leave petitions treated as appeals, ruling given retrospective effect
January 13, 2026   Case Laws Income Tax
Special-audit approval u/s 142(2A) lacked DIN and justification per Circular No.19/2019, held invalid; audit quashed for assessee
January 13, 2026   Case Laws Income Tax
Delay in filing Form No.10-IC to claim Section 115BAA concessional tax-condoned u/s 119(2)(b) after hardship shown
January 13, 2026   Case Laws Income Tax
Capital gains tax rate u/s 50/112 must follow binding ITAT Special Bench ruling; order set aside and remanded
January 13, 2026   Case Laws Income Tax
Validity of unsigned Section 148 notice declared void; reassessment proceedings based on it held invalid, relief for assessee
January 13, 2026   Case Laws Income Tax
Penalty orders u/s 271E/271D-whether limitation u/s 275(1)(c) runs from Assessing Officer's reference; therefore orders time-barred
January 13, 2026   Case Laws Income Tax
Seized incriminating documents and receipts determining tax additions for student fees, property investment, and stamp duty - partly upheld
January 13, 2026   Case Laws Income Tax
Residential status u/s 6(1) Explanation 1(b): stays below 182 days for 2017-20, s.115C Explanation (e) confirms non-resident
January 13, 2026   Case Laws Income Tax
Assessment time-barred u/s 153 due to missing competent-authority reference for Singapore exchange of information; assessment disallowed as barred by limitation
January 13, 2026   Case Laws Income Tax
Filing wrong ITR form (ITR-7 vs ITR-5) and disallowance of lawful business expenses; tribunal restores deductions, orders refiling and reassessment
January 13, 2026   Case Laws Income Tax
AMP payments and marketing salaries via credit-notes found genuine; disallowances deleted; no AMP reallocation; 14A limited
January 13, 2026   Case Laws Income Tax
Proprietary software held by taxpayer treated as intangible asset eligible for 60% depreciation allowance, overturning 25% limit
January 13, 2026   Case Laws Income Tax
Claiming new tax regime after late Form 10-IE and delayed return: new-regime election infirm; verification ordered and relief possible.
January 13, 2026   Case Laws Customs
Imported menthol-scented sweet supari classification dispute: seizure quashed, release for home consumption subject to duty bond; bank guarantee refused
January 13, 2026   Case Laws Customs
Imported fabric thickness discrepancy valuation fixed by contemporaneous imports at US$1.80/m, duties and penalties upheld.
January 13, 2026   Case Laws Customs
Classification of product as organic surface-active agent (surfactant) under CTH 3402; held classifiable at CTH 3402 4200 pending import verification
January 13, 2026   Case Laws Service Tax
Reimbursements to foreign representative office treated as mere expense recovery, not taxable consideration under reverse-charge; order set aside
January 13, 2026   Case Laws Service Tax
Appellants' receipts characterized as taxable services u/s 65B; liability sustained, one receipt exempted; extended limitation not invoked
January 13, 2026   Case Laws Customs
CKD/SKD air-conditioner components classifiable with finished units by essential character; prior advance ruling extended three years, FTA benefits possible

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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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