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    December 26, 2025   Case Laws Income Tax
    Marketing support and subcontracted client contracts: no agency permanent establishment under Article 5 DTAA; arm's-length pricing bars profit attribu...
    December 26, 2025   Case Laws Income Tax
    Tax assessment jurisdiction transfer u/s 127 for centralized investigation upheld; challenge claiming original station should assess dismissed
    December 26, 2025   Case Laws Income Tax
    Modified return after amalgamation/demerger u/s170A: fresh s.143(2) scrutiny notice for same year stayed as impermissible
    December 26, 2025   Case Laws Income Tax
    E-filing return utility blocking s.70(2) STCL set-off against STCG: authorities must update portal or accept paper s.139(5) return
    December 26, 2025   Case Laws Income Tax
    Delayed tax refund under Vivad Se Vishwas scheme: taxpayer awarded 6% interest and "interest on interest" for non-payment delay
    December 26, 2025   Case Laws Income Tax
    Ambiguous section 271(1)(c) tax penalty notice for "concealment" vs "inaccurate particulars" upheld as invalid; penalty deleted.
    December 26, 2025   Case Laws Income Tax
    Seizure of gold jewellery stock-in-trade during tax search under s132(1)(iii) challenged; ordered released without bank guarantee.
    December 26, 2025   Case Laws Income Tax
    Carry-forward of depreciation and business losses after demerger: s263 revision based on s72A(2) three-year condition struck down
    December 26, 2025   Case Laws Income Tax
    Purchase returns accounting discrepancy treated as excess purchases; s.270A "misreporting" penalty rejected and deleted on appeal
    December 26, 2025   Case Laws Income Tax
    Cash received under agreement to sell above threshold: section 271D penalty for alleged section 269SS breach set aside.
    December 26, 2025   Case Laws Income Tax
    Limited scrutiny of share premium and share application money: Section 68 addition and assessment quashed for invalid 143(2) notice
    December 26, 2025   Case Laws Income Tax
    Tax demand created later by s.154 rectification after "nil" assessment; s.220(2) interest deleted until fresh s.156 notice served.
    December 26, 2025   Case Laws Income Tax
    Flat-sale revenue recognition timing under project completion vs 25% completion threshold; addition deleted to avoid double taxation.
    December 26, 2025   Case Laws Income Tax
    Non-resident employee's foreign assignment salary for services entirely outside India held not accruing in India u/s5(2)(b)
    December 26, 2025   Case Laws Income Tax
    Transfer pricing on AE SBLC guarantee fees and loan interest benchmarked correctly; NBFC loan cash-credit addition deleted, R&D deduction allowed
    December 26, 2025   Case Laws Income Tax
    Cost-to-cost reimbursements for AE's marketing events and year-end service provisions: no TP mark-up, adjustment deleted; 115JB recompute
    December 26, 2025   Case Laws Income Tax
    Demonetisation cash deposits and s69 addition: whether already covered by s245D(4) settlement income; double-tax bar upheld, appeal dismissed
    December 26, 2025   Case Laws Income Tax
    Intra-group management service fees benchmarking under "Other Method": cost-plus markups accepted; Nil arm's-length price adjustment deleted.
    December 26, 2025   Case Laws Income Tax
    Transfer pricing comparables selection and working capital adjustment u/r 10B(1)(e)(iii), remanded for recomputation with rejected comparables include...
    December 26, 2025   Case Laws Benami Property
    Property purchases using appellant's funds held benami u/s2(9)(A); attachment upheld despite no cross-examination, appeals dismissed.
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December 26, 2025   Case Laws Income Tax
Marketing support and subcontracted client contracts: no agency permanent establishment under Article 5 DTAA; arm's-length pricing bars profit attribution.
December 26, 2025   Case Laws Income Tax
Tax assessment jurisdiction transfer u/s 127 for centralized investigation upheld; challenge claiming original station should assess dismissed
December 26, 2025   Case Laws Income Tax
Modified return after amalgamation/demerger u/s170A: fresh s.143(2) scrutiny notice for same year stayed as impermissible
December 26, 2025   Case Laws Income Tax
E-filing return utility blocking s.70(2) STCL set-off against STCG: authorities must update portal or accept paper s.139(5) return
December 26, 2025   Case Laws Income Tax
Delayed tax refund under Vivad Se Vishwas scheme: taxpayer awarded 6% interest and "interest on interest" for non-payment delay
December 26, 2025   Case Laws Income Tax
Ambiguous section 271(1)(c) tax penalty notice for "concealment" vs "inaccurate particulars" upheld as invalid; penalty deleted.
December 26, 2025   Case Laws Income Tax
Seizure of gold jewellery stock-in-trade during tax search under s132(1)(iii) challenged; ordered released without bank guarantee.
December 26, 2025   Case Laws Income Tax
Carry-forward of depreciation and business losses after demerger: s263 revision based on s72A(2) three-year condition struck down
December 26, 2025   Case Laws Income Tax
Purchase returns accounting discrepancy treated as excess purchases; s.270A "misreporting" penalty rejected and deleted on appeal
December 26, 2025   Case Laws Income Tax
Cash received under agreement to sell above threshold: section 271D penalty for alleged section 269SS breach set aside.
December 26, 2025   Case Laws Income Tax
Limited scrutiny of share premium and share application money: Section 68 addition and assessment quashed for invalid 143(2) notice
December 26, 2025   Case Laws Income Tax
Tax demand created later by s.154 rectification after "nil" assessment; s.220(2) interest deleted until fresh s.156 notice served.
December 26, 2025   Case Laws Income Tax
Flat-sale revenue recognition timing under project completion vs 25% completion threshold; addition deleted to avoid double taxation.
December 26, 2025   Case Laws Income Tax
Non-resident employee's foreign assignment salary for services entirely outside India held not accruing in India u/s5(2)(b)
December 26, 2025   Case Laws Income Tax
Transfer pricing on AE SBLC guarantee fees and loan interest benchmarked correctly; NBFC loan cash-credit addition deleted, R&D deduction allowed
December 26, 2025   Case Laws Income Tax
Cost-to-cost reimbursements for AE's marketing events and year-end service provisions: no TP mark-up, adjustment deleted; 115JB recompute
December 26, 2025   Case Laws Income Tax
Demonetisation cash deposits and s69 addition: whether already covered by s245D(4) settlement income; double-tax bar upheld, appeal dismissed
December 26, 2025   Case Laws Income Tax
Intra-group management service fees benchmarking under "Other Method": cost-plus markups accepted; Nil arm's-length price adjustment deleted.
December 26, 2025   Case Laws Income Tax
Transfer pricing comparables selection and working capital adjustment u/r 10B(1)(e)(iii), remanded for recomputation with rejected comparables included.
December 26, 2025   Case Laws Benami Property
Property purchases using appellant's funds held benami u/s2(9)(A); attachment upheld despite no cross-examination, appeals dismissed.

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Customs

Amends the Sea Cargo Manifest and Transshipment Regulations,...

Sea cargo manifest and transshipment filing deadlines extended, amending 2018 rules to shift key date to 31 March 2026.

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Customs January 2, 2026 Notifications
Amends the Sea Cargo Manifest and Transshipment Regulations, 2018 by substituting, in the Table after FORM-XII, the date specified at serial number 6 in column (3) with "31.03.2026". This defers the relevant deadline or effective date tied to that table entry until 31 March 2026, with the amendment taking effect from the date of publication in the Official Gazette.
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Acts Income Tax
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