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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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LLP

Amends the earlier notification establishing Regional Directors...

Commencement date for LLP Act Section 68A Regional Directors notification deferred, shifting start from 1 January to 16 February 2026

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LLP January 2, 2026 Notifications
Amends the earlier notification establishing Regional Directors under section 68A of the Limited Liability Partnership Act, 2008 by substituting the commencement date in paragraph 2 from "1st January, 2026" to "16th February, 2026", thereby deferring the operative date from which the notified establishment and functioning of such Regional Directors takes effect.
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Acts Income Tax
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