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    March 3, 2026   Case Laws GST
    Right to Personal Hearing: ineffective portal-only service requires alternate modes and fresh hearing before adjudication.
    March 3, 2026   Case Laws GST
    Effective service requirement: officers must explore alternative service modes beyond the GST portal and afford personal hearing; non-compliance voids...
    March 3, 2026   Case Laws Income Tax
    Cancelled transactions and reversal of consideration negate taxable income; assessments quashed where cancellation evidence was not considered.
    March 3, 2026   Case Laws Income Tax
    Invocation of Section 153C: reliance on external or public domain material or absence of AO satisfaction note invalidates proceedings.
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    Computation of limitation for reopening: ten-year window reckoned from end of the relevant assessment year, notice quashed.
    March 3, 2026   Case Laws Income Tax
    Estimate-based additions do not satisfy proof-of-concealment required for penalty; penalty deleted where addition rests on estimate.
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    Estimation of profit element in bogus purchases remitted for fresh adjudication to apply binding precedents and record reasons.
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    Estimation of undisclosed income on turnover is unsustainable where banking evidence and books support transactions, so additions deleted.
    March 3, 2026   Case Laws Income Tax
    Limitation under Section 153(3) bars final assessments if DRP directions are issued after the prescribed statutory window.
    March 3, 2026   Case Laws Income Tax
    Permanent Establishment under DTAA not established, so off the shelf software receipts not taxable as royalty and presumptive tax inapplicable.
    March 3, 2026   Case Laws Income Tax
    Arm's length price: Internal CUP remand for NCD benchmarking; fresh deduction claim admitted and statutory interest on refund directed.
    March 3, 2026   Case Laws Income Tax
    Onus to Prove Genuineness of Share Transactions: documentary proof can rebut suspicion and protect 10(38) LTCG exemption.
    March 3, 2026   Case Laws Income Tax
    Admission of Additional Grounds affirmed where facts are on record; reopening quashed when additions do not flow from recorded reasons.
    March 3, 2026   Case Laws Income Tax
    Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
    March 3, 2026   Case Laws Income Tax
    Transfer Pricing: royalty adjustment negated by prior appellate precedent; typographical error did not defeat infrastructure deduction claim.
    March 3, 2026   Case Laws Income Tax
    Relevant date for Section 54 exemption: completion with payment and possession within two years qualifies for relief.
    March 3, 2026   Case Laws Customs
    Customs Valuation Rule sequence: Chartered Engineer certificate alone cannot justify rejection of transaction value; reassessment set aside.
    March 3, 2026   Case Laws Customs
    Customs valuation principles: Rule 7 market surveys require contemporaneous comparable imports; unsupported valuations can be set aside.
    March 3, 2026   Case Laws Companies Law
    Class action maintainability: Section 245 covers past and continuing misconduct and permits claims against directors and third parties.
    March 3, 2026   Case Laws IBC
    Acknowledgment under Limitation Act renews limitation; recovery certificate and judicial exclusion made filing timely; statutory termination route req...
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March 3, 2026   Case Laws GST
Right to Personal Hearing: ineffective portal-only service requires alternate modes and fresh hearing before adjudication.
March 3, 2026   Case Laws GST
Effective service requirement: officers must explore alternative service modes beyond the GST portal and afford personal hearing; non-compliance voids orders.
March 3, 2026   Case Laws Income Tax
Cancelled transactions and reversal of consideration negate taxable income; assessments quashed where cancellation evidence was not considered.
March 3, 2026   Case Laws Income Tax
Invocation of Section 153C: reliance on external or public domain material or absence of AO satisfaction note invalidates proceedings.
March 3, 2026   Case Laws Income Tax
Computation of limitation for reopening: ten-year window reckoned from end of the relevant assessment year, notice quashed.
March 3, 2026   Case Laws Income Tax
Estimate-based additions do not satisfy proof-of-concealment required for penalty; penalty deleted where addition rests on estimate.
March 3, 2026   Case Laws Income Tax
Estimation of profit element in bogus purchases remitted for fresh adjudication to apply binding precedents and record reasons.
March 3, 2026   Case Laws Income Tax
Estimation of undisclosed income on turnover is unsustainable where banking evidence and books support transactions, so additions deleted.
March 3, 2026   Case Laws Income Tax
Limitation under Section 153(3) bars final assessments if DRP directions are issued after the prescribed statutory window.
March 3, 2026   Case Laws Income Tax
Permanent Establishment under DTAA not established, so off the shelf software receipts not taxable as royalty and presumptive tax inapplicable.
March 3, 2026   Case Laws Income Tax
Arm's length price: Internal CUP remand for NCD benchmarking; fresh deduction claim admitted and statutory interest on refund directed.
March 3, 2026   Case Laws Income Tax
Onus to Prove Genuineness of Share Transactions: documentary proof can rebut suspicion and protect 10(38) LTCG exemption.
March 3, 2026   Case Laws Income Tax
Admission of Additional Grounds affirmed where facts are on record; reopening quashed when additions do not flow from recorded reasons.
March 3, 2026   Case Laws Income Tax
Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing established.
March 3, 2026   Case Laws Income Tax
Transfer Pricing: royalty adjustment negated by prior appellate precedent; typographical error did not defeat infrastructure deduction claim.
March 3, 2026   Case Laws Income Tax
Relevant date for Section 54 exemption: completion with payment and possession within two years qualifies for relief.
March 3, 2026   Case Laws Customs
Customs Valuation Rule sequence: Chartered Engineer certificate alone cannot justify rejection of transaction value; reassessment set aside.
March 3, 2026   Case Laws Customs
Customs valuation principles: Rule 7 market surveys require contemporaneous comparable imports; unsupported valuations can be set aside.
March 3, 2026   Case Laws Companies Law
Class action maintainability: Section 245 covers past and continuing misconduct and permits claims against directors and third parties.
March 3, 2026   Case Laws IBC
Acknowledgment under Limitation Act renews limitation; recovery certificate and judicial exclusion made filing timely; statutory termination route required.

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Income Tax

Whether consideration for ancillary support services connected...

Income tax treatment of ancillary support services for software licenses under IndiaSingapore DTAA found not to be FTS, relief granted

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Income Tax January 28, 2026 Case Laws AT
Whether consideration for ancillary support services connected to software license distribution constitutes Fee for Technical Services under the IndiaSingapore DTAA. The tribunal found the services were ancillary and subsidiary to software sales, including maintenance and technical support obligations under the parties' licence and partner agreements, and thus not characterisable as FTS or as "make available" independent services; consequence: the assessing officer/TPA/DRP findings treating the receipts as FTS were not justified and were disallowed to that extent.
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Acts Income Tax
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