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    March 20, 2026   Case Laws Income Tax
    Extended limitation for reassessment not triggered by procedural remand; ordinary limitation applied and reassessment held time barred.
    March 20, 2026   Case Laws Income Tax
    Irrevocability of public charitable trusts arises by law; lack of an express clause cannot justify registration rejection.
    March 20, 2026   Case Laws Income Tax
    Service by Email: recorded email addresses validate notices but pandemic excuse may condone appeal delay, subject to deposit.
    March 20, 2026   Case Laws Income Tax
    Slump Sale qualifies where consideration is lump sum without asset wise valuation; capital gains computed under special net worth rule.
    March 20, 2026   Case Laws Income Tax
    Depreciation on Goodwill denied where not capitalised; SEZ unit loss set off remitted for AO verification and recomputation.
    March 20, 2026   Case Laws Income Tax
    Reopening of assessment invalid where approval rests on erroneous facts; onus under section 68 shifts to AO to rebut documentary proof.
    March 20, 2026   Case Laws Income Tax
    Allowability of business expenditure: captive power costs upheld as deductible; Rule 8D disallowance limited to exempt income.
    March 20, 2026   Case Laws Income Tax
    Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
    March 20, 2026   Case Laws Income Tax
    Indexed cost of improvement: 80% of claimed improvement allowed despite incomplete proof, AO directed to recompute deduction.
    March 20, 2026   Case Laws Income Tax
    Audi Alteram Partem breach invalidates disallowance where authorities ignore available documentary evidence; addition set aside.
    March 20, 2026   Case Laws Income Tax
    Electronic chat evidence: WhatsApp messages alone cannot prove unexplained investment; corroborative seized material and statements required.
    March 20, 2026   Case Laws Income Tax
    Jurisdiction under Section 153C invalid for lack of incriminating material; additions deleted and earlier years quashed.
    March 20, 2026   Case Laws Income Tax
    Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
    March 20, 2026   Case Laws Income Tax
    Mandatory Signature Requirement: unsigned income tax notices are invalid and cannot sustain reassessment proceedings under law.
    March 20, 2026   Case Laws Customs
    Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
    March 20, 2026   Case Laws Customs
    Improper import standard: invalid inspection certificates alone do not justify confiscation; penalties require proof of abetment mens rea.
    March 20, 2026   Case Laws Customs
    Presumption of smuggling: possession, recovery and an un retracted admission sustain confiscation when lawful origin is not proved.
    March 20, 2026   Case Laws Customs
    Customs Broker Liability: penalty requires specific proof of the broker's facilitation of export overvaluation, or it must be set aside.
    March 20, 2026   Case Laws Customs
    Classification of printed technical documents: specific Chapter 49.01 entry prevails, enabling claimed customs exemptions for imported manuals and rep...
    March 20, 2026   Case Laws Customs
    Specific tariff classification: APIs and bulk drugs are treated as drugs and attract IGST under the specific entry.
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March 20, 2026   Case Laws Income Tax
Extended limitation for reassessment not triggered by procedural remand; ordinary limitation applied and reassessment held time barred.
March 20, 2026   Case Laws Income Tax
Irrevocability of public charitable trusts arises by law; lack of an express clause cannot justify registration rejection.
March 20, 2026   Case Laws Income Tax
Service by Email: recorded email addresses validate notices but pandemic excuse may condone appeal delay, subject to deposit.
March 20, 2026   Case Laws Income Tax
Slump Sale qualifies where consideration is lump sum without asset wise valuation; capital gains computed under special net worth rule.
March 20, 2026   Case Laws Income Tax
Depreciation on Goodwill denied where not capitalised; SEZ unit loss set off remitted for AO verification and recomputation.
March 20, 2026   Case Laws Income Tax
Reopening of assessment invalid where approval rests on erroneous facts; onus under section 68 shifts to AO to rebut documentary proof.
March 20, 2026   Case Laws Income Tax
Allowability of business expenditure: captive power costs upheld as deductible; Rule 8D disallowance limited to exempt income.
March 20, 2026   Case Laws Income Tax
Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted documentary proof.
March 20, 2026   Case Laws Income Tax
Indexed cost of improvement: 80% of claimed improvement allowed despite incomplete proof, AO directed to recompute deduction.
March 20, 2026   Case Laws Income Tax
Audi Alteram Partem breach invalidates disallowance where authorities ignore available documentary evidence; addition set aside.
March 20, 2026   Case Laws Income Tax
Electronic chat evidence: WhatsApp messages alone cannot prove unexplained investment; corroborative seized material and statements required.
March 20, 2026   Case Laws Income Tax
Jurisdiction under Section 153C invalid for lack of incriminating material; additions deleted and earlier years quashed.
March 20, 2026   Case Laws Income Tax
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mine-closure deductions sustained.
March 20, 2026   Case Laws Income Tax
Mandatory Signature Requirement: unsigned income tax notices are invalid and cannot sustain reassessment proceedings under law.
March 20, 2026   Case Laws Customs
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties and orders
March 20, 2026   Case Laws Customs
Improper import standard: invalid inspection certificates alone do not justify confiscation; penalties require proof of abetment mens rea.
March 20, 2026   Case Laws Customs
Presumption of smuggling: possession, recovery and an un retracted admission sustain confiscation when lawful origin is not proved.
March 20, 2026   Case Laws Customs
Customs Broker Liability: penalty requires specific proof of the broker's facilitation of export overvaluation, or it must be set aside.
March 20, 2026   Case Laws Customs
Classification of printed technical documents: specific Chapter 49.01 entry prevails, enabling claimed customs exemptions for imported manuals and reports.
March 20, 2026   Case Laws Customs
Specific tariff classification: APIs and bulk drugs are treated as drugs and attract IGST under the specific entry.

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Income Tax

Dependent Agent Permanent Establishment under Article 5(4) was...

Dependent Agent Permanent Establishment: habitual authority to conclude contracts must be proven; distributors as independent resellers defeated DAPE.

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Income Tax March 10, 2026 Case Laws AT
Dependent Agent Permanent Establishment under Article 5(4) was examined: the revenue must prove an agent in India habitually exercises authority to conclude contracts or meets alternative sub conditions; sample distributor agreements showed non exclusive distributors purchasing, selling and bearing risk in their own name, with only a limited lawful maximum resale price constraint. Certification of resellers was treated as quality control, not control converting distributors into dependent agents. Website descriptions did not establish customer specific tailoring. As conditions of Article 5(4) were not satisfied, no DAPE arose and attribution of profits to a PE was unwarranted.
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Acts Income Tax
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