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    February 17, 2026   Case Laws Income Tax
    Withholding Certificate Rate: NIL certificate ordered after 15% issuance; authority directed to issue annual NIL certificates on timely application.
    February 17, 2026   Case Laws Income Tax
    Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
    February 17, 2026   Case Laws Income Tax
    Reopening validity under section 151 requires specified prior sanction; late reassessment notice invalid and quashed.
    February 17, 2026   Case Laws Income Tax
    Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
    February 17, 2026   Case Laws Income Tax
    Deduction under 80-IC reduced where profit suppression in non-eligible unit found; net profit rate averaged to recompute deduction.
    February 17, 2026   Case Laws Income Tax
    Revisionary jurisdiction affirmed: trustee power to add beneficiaries justified reconsideration; AO required to verify genuineness of claims.
    February 17, 2026   Case Laws Income Tax
    Revisional jurisdiction based on conjecture and audit objection is vitiated, so assessing officer's allowance of R&D deduction restored.
    February 17, 2026   Case Laws Income Tax
    Permanent establishment: interest on an income-tax refund treated as treaty interest, capped at a 15% source tax if no PE.
    February 17, 2026   Case Laws Income Tax
    Penalty under section 271AAB reduced where search team failed to probe sources and inform parties under section 132(4).
    February 17, 2026   Case Laws Income Tax
    Revisionary powers improperly exercised where remand for fresh inquiry replaced required independent enquiry, resulting in set aside.
    February 17, 2026   Case Laws Income Tax
    Assessment jurisdiction under Section 153C required where search yields incriminating material of a third party; AO cannot use Section 147.
    February 17, 2026   Case Laws Income Tax
    Deduction under Section 10A: slump-sale transfer alone does not bar relief; some units remitted for factual verification.
    February 17, 2026   Case Laws Benami Property
    Benami transaction definition applies where property remained in a nominee's name post-amendment, sustaining provisional attachment.
    February 17, 2026   Case Laws Customs
    Valuation by Market Survey upheld; burden shifts to importer to rebut valuation and lack of legal question renders appeal unmaintainable.
    February 17, 2026   Case Laws Customs
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    February 17, 2026   Case Laws Customs
    Classification of imported metal as waste and scrap upheld where revaluation rested on unsupported usable-material claims.
    February 17, 2026   Case Laws Customs
    Wilful mis-statement or suppression of facts: penalty cannot be imposed for bona fide incorrect self-assessment based on exemption belief.
    February 17, 2026   Case Laws IBC
    Spectrum as public trust and licensing control prevent its inclusion in corporate insolvency estates under the IBC.
    February 17, 2026   Case Laws IBC
    Limitation and acknowledgement: restructuring and working capital acknowledgments can reset date of default, keeping a Section 7 filing timely.
    February 17, 2026   Case Laws IBC
    Threshold applicability in insolvency petitions limits relief when default date falls outside prescribed period, affecting interest claims.
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February 17, 2026   Case Laws Income Tax
Withholding Certificate Rate: NIL certificate ordered after 15% issuance; authority directed to issue annual NIL certificates on timely application.
February 17, 2026   Case Laws Income Tax
Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision should be considered.
February 17, 2026   Case Laws Income Tax
Reopening validity under section 151 requires specified prior sanction; late reassessment notice invalid and quashed.
February 17, 2026   Case Laws Income Tax
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustment.
February 17, 2026   Case Laws Income Tax
Deduction under 80-IC reduced where profit suppression in non-eligible unit found; net profit rate averaged to recompute deduction.
February 17, 2026   Case Laws Income Tax
Revisionary jurisdiction affirmed: trustee power to add beneficiaries justified reconsideration; AO required to verify genuineness of claims.
February 17, 2026   Case Laws Income Tax
Revisional jurisdiction based on conjecture and audit objection is vitiated, so assessing officer's allowance of R&D deduction restored.
February 17, 2026   Case Laws Income Tax
Permanent establishment: interest on an income-tax refund treated as treaty interest, capped at a 15% source tax if no PE.
February 17, 2026   Case Laws Income Tax
Penalty under section 271AAB reduced where search team failed to probe sources and inform parties under section 132(4).
February 17, 2026   Case Laws Income Tax
Revisionary powers improperly exercised where remand for fresh inquiry replaced required independent enquiry, resulting in set aside.
February 17, 2026   Case Laws Income Tax
Assessment jurisdiction under Section 153C required where search yields incriminating material of a third party; AO cannot use Section 147.
February 17, 2026   Case Laws Income Tax
Deduction under Section 10A: slump-sale transfer alone does not bar relief; some units remitted for factual verification.
February 17, 2026   Case Laws Benami Property
Benami transaction definition applies where property remained in a nominee's name post-amendment, sustaining provisional attachment.
February 17, 2026   Case Laws Customs
Valuation by Market Survey upheld; burden shifts to importer to rebut valuation and lack of legal question renders appeal unmaintainable.
February 17, 2026   Case Laws Customs
Freedom to carry on trade is subject to reasonable restrictions; administrative circulars may be valid if non-arbitrary.
February 17, 2026   Case Laws Customs
Classification of imported metal as waste and scrap upheld where revaluation rested on unsupported usable-material claims.
February 17, 2026   Case Laws Customs
Wilful mis-statement or suppression of facts: penalty cannot be imposed for bona fide incorrect self-assessment based on exemption belief.
February 17, 2026   Case Laws IBC
Spectrum as public trust and licensing control prevent its inclusion in corporate insolvency estates under the IBC.
February 17, 2026   Case Laws IBC
Limitation and acknowledgement: restructuring and working capital acknowledgments can reset date of default, keeping a Section 7 filing timely.
February 17, 2026   Case Laws IBC
Threshold applicability in insolvency petitions limits relief when default date falls outside prescribed period, affecting interest claims.

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Income Tax

Addition treating commission receipt as unexplained cash credit...

Commission income and foreign joint venture investment questioned u/s68; travel, rent and salary disallowances all deleted

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Income Tax December 31, 2025 Case Laws AT
Addition treating commission receipt as unexplained cash credit was deleted because the AO showed no basis to invoke s.68 and the receipt was from an Indian payer within India, making foreign remittance formalities irrelevant; revenue's ground failed. Addition under s.68 for alleged unexplained investment in a foreign joint venture was deleted since evidence showed the investment was made in FY 2001-02 and was reflected as investment at cost, hence not taxable in the relevant year. Ad hoc disallowance of 10% domestic/foreign travel was deleted for lack of specific defects and absence of cash payments exceeding the alleged threshold. Disallowance of rent paid to a director was deleted as genuineness/business purpose was not in doubt and the recipient offered it to tax. Salary disallowance was deleted based on ledger, bank and TDS evidence. - ITAT
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Acts Income Tax
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