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    March 21, 2026   Case Laws Income Tax
    Expense apportionment: matching recovery treated as business income negates disallowance, Tribunal deleted additions for power fuel and maintenance
    March 21, 2026   Case Laws Income Tax
    Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
    March 21, 2026   Case Laws Income Tax
    Transfer Pricing on intra-group steam: adjustment deleted; REC treated as capital receipts; enhanced deduction remitted for verification.
    March 21, 2026   Case Laws Income Tax
    Deemed nullity of income declaration permits addition as unexplained investment, but tax on that addition computed at 30% not 60%.
    March 21, 2026   Case Laws Income Tax
    Natural justice breach: denial of cross-examination on third-party seized material led to deletion of additions under s.69B.
    March 21, 2026   Case Laws Income Tax
    Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
    March 21, 2026   Case Laws Income Tax
    Working partner remuneration limits upheld where deed adopts statutory book profit definition; payments within statutory limits allowed.
    March 21, 2026   Case Laws Income Tax
    Exemption for Urban Local Body affirmed where Revenue dropped reassessment and assessed income was deleted accordingly.
    March 21, 2026   Case Laws Income Tax
    Agricultural land classification: land beyond municipal limits is not a capital asset; reassessment vitiated by lack of natural justice.
    March 21, 2026   Case Laws Customs
    Extraordinary writ jurisdiction declined and limitation/time-bar plea directed to adjudicating authority for decision under law.
    March 21, 2026   Case Laws Customs
    Beneficial Construction of Retrospective Amendment: substitution correcting an omission entitled importer to exemption and quashed contrary orders.
    March 21, 2026   Case Laws Customs
    SAFTA exemption entitlement can be claimed belatedly if eligibility is established, and provisional assessments must be reopened for consideration.
    March 21, 2026   Case Laws Customs
    Due Diligence: Broker KYC met regulatory standard, revocation set aside and licence restored after hearsay and covert survey evidence rejected.
    March 21, 2026   Case Laws Customs
    Classification based exemption where documentary evidence and Out of Charge exists leads to BCD and SWS demands being set aside.
    March 21, 2026   Case Laws Customs
    Actual-User and Non-Transferability: failure to prove compliance sustained demand and confiscation; procedural defect set aside penalty.
    March 21, 2026   Case Laws Customs
    Suitability-for-use test confirms DVRs engineered for Hawk aircraft are parts of aircraft, not general video apparatus.
    March 21, 2026   Case Laws Customs
    Export benefit retention upheld where exported replacement consignments satisfy the export transaction, so reversal not required.
    March 21, 2026   Case Laws Companies Law
    Validity of Oral Family Settlement: non-compliance with buy-out terms prevents asserted management transfer; forensic probe may be sought later.
    March 21, 2026   Case Laws Companies Law
    Unregistered agreement for sale lacks title effect; leave to sue granted but conveyance refused absent proven entitlement.
    March 21, 2026   Case Laws IBC
    Fairness in NRRA assignments must balance transparency with finality; belated non compliant bids and post sale acquiescence can bar challenges.
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March 21, 2026   Case Laws Income Tax
Expense apportionment: matching recovery treated as business income negates disallowance, Tribunal deleted additions for power fuel and maintenance
March 21, 2026   Case Laws Income Tax
Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh assessment.
March 21, 2026   Case Laws Income Tax
Transfer Pricing on intra-group steam: adjustment deleted; REC treated as capital receipts; enhanced deduction remitted for verification.
March 21, 2026   Case Laws Income Tax
Deemed nullity of income declaration permits addition as unexplained investment, but tax on that addition computed at 30% not 60%.
March 21, 2026   Case Laws Income Tax
Natural justice breach: denial of cross-examination on third-party seized material led to deletion of additions under s.69B.
March 21, 2026   Case Laws Income Tax
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification.
March 21, 2026   Case Laws Income Tax
Working partner remuneration limits upheld where deed adopts statutory book profit definition; payments within statutory limits allowed.
March 21, 2026   Case Laws Income Tax
Exemption for Urban Local Body affirmed where Revenue dropped reassessment and assessed income was deleted accordingly.
March 21, 2026   Case Laws Income Tax
Agricultural land classification: land beyond municipal limits is not a capital asset; reassessment vitiated by lack of natural justice.
March 21, 2026   Case Laws Customs
Extraordinary writ jurisdiction declined and limitation/time-bar plea directed to adjudicating authority for decision under law.
March 21, 2026   Case Laws Customs
Beneficial Construction of Retrospective Amendment: substitution correcting an omission entitled importer to exemption and quashed contrary orders.
March 21, 2026   Case Laws Customs
SAFTA exemption entitlement can be claimed belatedly if eligibility is established, and provisional assessments must be reopened for consideration.
March 21, 2026   Case Laws Customs
Due Diligence: Broker KYC met regulatory standard, revocation set aside and licence restored after hearsay and covert survey evidence rejected.
March 21, 2026   Case Laws Customs
Classification based exemption where documentary evidence and Out of Charge exists leads to BCD and SWS demands being set aside.
March 21, 2026   Case Laws Customs
Actual-User and Non-Transferability: failure to prove compliance sustained demand and confiscation; procedural defect set aside penalty.
March 21, 2026   Case Laws Customs
Suitability-for-use test confirms DVRs engineered for Hawk aircraft are parts of aircraft, not general video apparatus.
March 21, 2026   Case Laws Customs
Export benefit retention upheld where exported replacement consignments satisfy the export transaction, so reversal not required.
March 21, 2026   Case Laws Companies Law
Validity of Oral Family Settlement: non-compliance with buy-out terms prevents asserted management transfer; forensic probe may be sought later.
March 21, 2026   Case Laws Companies Law
Unregistered agreement for sale lacks title effect; leave to sue granted but conveyance refused absent proven entitlement.
March 21, 2026   Case Laws IBC
Fairness in NRRA assignments must balance transparency with finality; belated non compliant bids and post sale acquiescence can bar challenges.

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Income Tax

Whether a dependent agent constituted a permanent establishment:...

Distributor's activities under distribution agreement not a dependent-agent permanent establishment; software/training payments taxed as FTS

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Income Tax January 20, 2026 Case Laws AT
Whether a dependent agent constituted a permanent establishment: the tribunal examined the distribution agreement and found express clauses denying authority to bind the principal, independent purchase/resale on FOB terms, entrepreneurial, inventory and credit risk borne by the local distributor, and absence of evidence that the distributor habitually concluded contracts, maintained stock or secured orders for the foreign enterprise; therefore no Agency PE arose and attribution of 35% of offshore sales to India was rejected. Whether payments to the distributor constituted fees for technical/managerial services: the tribunal held the assessees' provision of software, web/cloud services, training and managerial support fell within "managerial/technical" services under Article 13 and sustained taxation as FTS. - ITAT
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