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    March 5, 2026   Case LawsMoney Laundering
    Prima facie satisfaction under PMLA supports conditional bail when investigation is substantially complete and risks are mitigable.
    March 5, 2026   Case LawsMoney Laundering
    Provisional attachment of proceeds of crime upheld as tainted assets traced to a bitcoin scheme; attachment valid despite non-accused possession.
    March 5, 2026   Case LawsMoney Laundering
    Proceeds of crime: provisional attachment confirmed; equivalent value attachment and acquisition date fair market value upheld, Covid exclusion preser...
    March 5, 2026   Case LawsService Tax
    Extended limitation under the proviso requires proven fraud or suppression; absent that, extended demand is unsustainable.
    March 5, 2026   Case LawsCentral Excise
    Corroborative Evidence required: seizures and duty demands unsupported by input output theory were set aside for lack of positive proof.
    March 5, 2026   Case LawsVAT / Sales Tax
    Surcharge on tax leviable in addition to tax on declared goods when computed on tax payable.
    March 3, 2026   Case LawsGST
    Limitation period exclusion requires fresh adjudication of refund claims; administrative rejections cannot ignore the judicial exclusion.
    March 3, 2026   Case LawsGST
    Right to Personal Hearing: ineffective portal-only service requires alternate modes and fresh hearing before adjudication.
    March 3, 2026   Case LawsGST
    Effective service requirement: officers must explore alternative service modes beyond the GST portal and afford personal hearing; non-compliance voids...
    March 3, 2026   Case LawsIncome Tax
    Cancelled transactions and reversal of consideration negate taxable income; assessments quashed where cancellation evidence was not considered.
    March 3, 2026   Case LawsIncome Tax
    Invocation of Section 153C: reliance on external or public domain material or absence of AO satisfaction note invalidates proceedings.
    March 3, 2026   Case LawsIncome Tax
    Computation of limitation for reopening: ten-year window reckoned from end of the relevant assessment year, notice quashed.
    March 3, 2026   Case LawsIncome Tax
    Estimate-based additions do not satisfy proof-of-concealment required for penalty; penalty deleted where addition rests on estimate.
    March 3, 2026   Case LawsIncome Tax
    Estimation of profit element in bogus purchases remitted for fresh adjudication to apply binding precedents and record reasons.
    March 3, 2026   Case LawsIncome Tax
    Estimation of undisclosed income on turnover is unsustainable where banking evidence and books support transactions, so additions deleted.
    March 3, 2026   Case LawsIncome Tax
    Limitation under Section 153(3) bars final assessments if DRP directions are issued after the prescribed statutory window.
    March 3, 2026   Case LawsIncome 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 LawsIncome 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 LawsIncome Tax
    Onus to Prove Genuineness of Share Transactions: documentary proof can rebut suspicion and protect 10(38) LTCG exemption.
    March 3, 2026   Case LawsIncome Tax
    Admission of Additional Grounds affirmed where facts are on record; reopening quashed when additions do not flow from recorded reasons.
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    March 5, 2026   Case Laws Money Laundering
    Prima facie satisfaction under PMLA supports conditional bail when investigation is substantially complete and risks are mitigable.
    March 5, 2026   Case Laws Money Laundering
    Provisional attachment of proceeds of crime upheld as tainted assets traced to a bitcoin scheme; attachment valid despite non-accused possession.
    March 5, 2026   Case Laws Money Laundering
    Proceeds of crime: provisional attachment confirmed; equivalent value attachment and acquisition date fair market value upheld, Covid exclusion preserves 180 day rule.
    March 5, 2026   Case Laws Service Tax
    Extended limitation under the proviso requires proven fraud or suppression; absent that, extended demand is unsustainable.
    March 5, 2026   Case Laws Central Excise
    Corroborative Evidence required: seizures and duty demands unsupported by input output theory were set aside for lack of positive proof.
    March 5, 2026   Case Laws VAT / Sales Tax
    Surcharge on tax leviable in addition to tax on declared goods when computed on tax payable.
    March 3, 2026   Case Laws GST
    Limitation period exclusion requires fresh adjudication of refund claims; administrative rejections cannot ignore the judicial exclusion.
    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.

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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 TaxMarch 10, 2026Case LawsAT
      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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