Just a moment...

⚠ ✕
❮ Top
☎ Help
☰
×

By creating an account you can:

Logo TaxTMI
Keyword Search :
AI Tools : New
Ask tax questions in natural language. Powered by AI trained on the TaxTMI legal database. Use AI Tools ➞
Call Us / Help / Feedback✕

Contact Us At :

✉ E-mail: [email protected]

✆ Call / WhatsApp at: +91 99117 96707

For more information, Check Contact Us

FAQs :

To know Frequently Asked Questions, Check FAQs

Most Asked Video Tutorials :

For more tutorials, Check Video Tutorials

Submit Feedback/Suggestion :

Email :
Please provide your email address so we can follow up on your feedback.
Category :
Description :
Min 15 characters 0/2000
Make Most of Text Search ✕
  1. Checkout this video tutorial: How to search effectively on TaxTMI.
  2. Put words in double quotes for exact word search, eg: "income tax"
  3. Avoid noise words such as : 'and, of, the, a'
  4. Sort by Relevance to get the most relevant document.
  5. Press Enter to add multiple terms/multiple phrases, and then click on Search to Search.
    6. Text Search
  6. The system will try to fetch results that contains ALL your words.
  7. Once you add keywords, you'll see a new 'Search In' filter that makes your results even more precise.
    8. Text Search
╳
Add to...
You have not created any category. Kindly create one to bookmark this item!
✕
Create New Category
Hide
Title :
Description :
❮❮ Hide
❮ Default View
Expand ❯❯
Close ✕
🔎 Highlights - Adv. Search ❯
TEXT SEARCH:

Press 'Enter' to add multiple search terms. Rules for Better Search

Search In:
Main Text + AI Text ❯
  • Main Text
  • Main Text + AI Text
  • AI Text
Law:
---- All Laws---- ❯
  • ---- All Laws----
  • Income Tax
  • Direct Taxes
  • Benami Property
  • Central GST Laws
  • SGST - State GST Laws
  • Customs
  • FTP - Foreign Trade Policy
  • SEZ - Special Economic Zone
  • FEMA - Foreign Exchange Management
  • Companies Law
  • SEBI - Securities & Exchange Board of India
  • IBC - Insolvency and Bankruptcy
  • Law of Competition
  • PMLA - Money-Laundering
  • Indian Laws
  • Bill / Finance Bills
  • Wealth Tax
  • Service Tax
  • Central Excise
  • VAT / Sales Tax
Month:
---- All Months ---- ❯
  • ---- All Months ----
  • January
  • February
  • March
  • April
  • May
  • June
  • July
  • August
  • September
  • October
  • November
  • December
Year:
---- All Years ---- ❯
  • ---- All Years ----
  • 2026
  • 2025
  • 2024
  • 2023
  • 2022
  • 2021
  • 2020
  • 2019
  • 2018
  • 2017
  • 2016
  • 2015
  • 2014
  • 2013
  • 2012
  • 2011
Sort By: ?
In Sort By 'Default', exact matches for text search are shown at the top, followed by the remaining results in their regular order.
Relevance Default Date
    January 20, 2026   Case Laws GST
    Belated input tax credit claims and GSTR mismatch require re-adjudication; assessment quashed and remitted, conditional relief.
    January 20, 2026   Case Laws GST
    Blocking electronic input tax credit u/r 86A requires independent reasoned satisfaction; authority directed to pass fresh speaking order
    January 20, 2026   Case Laws GST
    Legality of arrest and non-production after medical transfer: challenge rejected as arrest supported by material and transfer excused non-production
    January 20, 2026   Case Laws GST
    Jurisdiction to issue show-cause notice u/s74 CGST/MGST after para 2 of Notification No.11/2017 struck down; reply affidavit ordered
    January 20, 2026   Case Laws Income Tax
    Verification of claimed TDS credits by assessing officers must precede waiver; directions to modify tax software set aside
    January 20, 2026   Case Laws Income Tax
    Reconciled challan tax credits and return of seized cash with interest ordered to be refunded within 30 days
    January 20, 2026   Case Laws Income Tax
    Requirement of recorded satisfaction before Section 14A/Rule 8D disallowance of claimed expenditure; addition invalidated on that ground
    January 20, 2026   Case Laws Income Tax
    Revisional order directing initiation of penalty u/s271E without Assessing Officer's recorded satisfaction set aside on appeal
    January 20, 2026   Case Laws Income Tax
    Interest on enhanced compensation held taxable u/s56(2)(viii) read with s.145B(1); s.10(37) exemption denied, revision u/s263 upheld
    January 20, 2026   Case Laws Income Tax
    Straight-line lease rental accounting change results in penalty quashed where disclosed accounts and bona fide arguable accounting interpretation exis...
    January 20, 2026   Case Laws Income Tax
    Distributor's activities under distribution agreement not a dependent-agent permanent establishment; software/training payments taxed as FTS
    January 20, 2026   Case Laws Income Tax
    Alleged bogus purchases, unexplained expenditure and trial-balance gross-profit adjustments held unsupported; assessment additions deleted for taxpaye...
    January 20, 2026   Case Laws Income Tax
    Cross-border receipts for flight data, software licences and services not "royalty" under Article 12 DTAA; treated as business income
    January 20, 2026   Case Laws Income Tax
    Allocation of enhanced FSI/TDR proceeds between cooperative society and individual flat-owners; tribunal deletes society LTCG addition, remits 80P ver...
    January 20, 2026   Case Laws Income Tax
    Non-maintenance of item-wise/month-wise stock registers not valid ground to reject audited books; gross profit uplift deleted u/s145
    January 20, 2026   Case Laws Income Tax
    Charitable trust investments in trustee-interested partnership breach prescribed investment mode, exemption disallowed and income taxed at top rate
    January 20, 2026   Case Laws Indian Laws
    Erstwhile directors' liability for cheque dishonour after IRP appointment u/s 138 - summoning quashed, complaint dismissed
    January 20, 2026   Case Laws Income Tax
    Deduction for interest and dividends from co-operative banks upheld where AO's plausible view prevents revisionary jurisdiction; appeal allowed.
    January 20, 2026   Case Laws Customs
    Provisional release of imported goods: 100% bank guarantee deemed excessive; reduced to 50% of estimated differential duty
    January 20, 2026   Case Laws Customs
    Foreign-origin cigarettes found in seized vehicle - appellant not liable u/ss 112(a), 112(b); penalties annulled; concealment goods forfeited
❮
❯
❯❯
Maximize Maximize Maximize
0 / 200
Expand Note
Add to Folder

No Folders have been created

+

Are you sure you want to delete "My most important" ?

NOTE:

Open Link
Highlights
Showing Results for :
Reset Filters
Results Found:
Show All Summaries Hide All Summaries
January 20, 2026   Case Laws GST
Belated input tax credit claims and GSTR mismatch require re-adjudication; assessment quashed and remitted, conditional relief.
January 20, 2026   Case Laws GST
Blocking electronic input tax credit u/r 86A requires independent reasoned satisfaction; authority directed to pass fresh speaking order
January 20, 2026   Case Laws GST
Legality of arrest and non-production after medical transfer: challenge rejected as arrest supported by material and transfer excused non-production
January 20, 2026   Case Laws GST
Jurisdiction to issue show-cause notice u/s74 CGST/MGST after para 2 of Notification No.11/2017 struck down; reply affidavit ordered
January 20, 2026   Case Laws Income Tax
Verification of claimed TDS credits by assessing officers must precede waiver; directions to modify tax software set aside
January 20, 2026   Case Laws Income Tax
Reconciled challan tax credits and return of seized cash with interest ordered to be refunded within 30 days
January 20, 2026   Case Laws Income Tax
Requirement of recorded satisfaction before Section 14A/Rule 8D disallowance of claimed expenditure; addition invalidated on that ground
January 20, 2026   Case Laws Income Tax
Revisional order directing initiation of penalty u/s271E without Assessing Officer's recorded satisfaction set aside on appeal
January 20, 2026   Case Laws Income Tax
Interest on enhanced compensation held taxable u/s56(2)(viii) read with s.145B(1); s.10(37) exemption denied, revision u/s263 upheld
January 20, 2026   Case Laws Income Tax
Straight-line lease rental accounting change results in penalty quashed where disclosed accounts and bona fide arguable accounting interpretation existed
January 20, 2026   Case Laws Income Tax
Distributor's activities under distribution agreement not a dependent-agent permanent establishment; software/training payments taxed as FTS
January 20, 2026   Case Laws Income Tax
Alleged bogus purchases, unexplained expenditure and trial-balance gross-profit adjustments held unsupported; assessment additions deleted for taxpayer
January 20, 2026   Case Laws Income Tax
Cross-border receipts for flight data, software licences and services not "royalty" under Article 12 DTAA; treated as business income
January 20, 2026   Case Laws Income Tax
Allocation of enhanced FSI/TDR proceeds between cooperative society and individual flat-owners; tribunal deletes society LTCG addition, remits 80P verification
January 20, 2026   Case Laws Income Tax
Non-maintenance of item-wise/month-wise stock registers not valid ground to reject audited books; gross profit uplift deleted u/s145
January 20, 2026   Case Laws Income Tax
Charitable trust investments in trustee-interested partnership breach prescribed investment mode, exemption disallowed and income taxed at top rate
January 20, 2026   Case Laws Indian Laws
Erstwhile directors' liability for cheque dishonour after IRP appointment u/s 138 - summoning quashed, complaint dismissed
January 20, 2026   Case Laws Income Tax
Deduction for interest and dividends from co-operative banks upheld where AO's plausible view prevents revisionary jurisdiction; appeal allowed.
January 20, 2026   Case Laws Customs
Provisional release of imported goods: 100% bank guarantee deemed excessive; reduced to 50% of estimated differential duty
January 20, 2026   Case Laws Customs
Foreign-origin cigarettes found in seized vehicle - appellant not liable u/ss 112(a), 112(b); penalties annulled; concealment goods forfeited

Highlights

Back

All Highlights

Showing Results for :
Reset Filters
No Records Found

Highlights

Home › Highlights › Income Tax › 2026 › March, 2026 › This
Back

All Highlights

whatsapp Join Channel
Showing Results for : Reset Filters
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.

Contents
Summary
Note

Note

-

Bookmark

Print

Print

Print Options

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.
View Source View

Topics

Acts Income Tax
Next ➔