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    September 1, 2026   Case Laws Income Tax
    Transfer-pricing benchmarking requires proven COVID costs, consistent TNMM classifications, and reliable internal CUP comparability before adjustments...
    September 1, 2026   Case Laws Income Tax
    Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
    September 1, 2026   Case Laws Income Tax
    Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
    September 1, 2026   Case Laws Income Tax
    Transfer-pricing comparability requires aligned related-party exposure, ownership profile, revenue model and sourcing-support functions to prevent dis...
    September 1, 2026   Case Laws Income Tax
    Assessment jurisdiction requires valid statutory transfer and timely scrutiny notice; administrative reassignment cannot sustain proceedings.
    September 1, 2026   Case Laws Income Tax
    TDS on statutory market fees and pass-through procurement payments did not trigger contract withholding disallowance.
    September 1, 2026   Case Laws Income Tax
    Binding Dispute Resolution Panel directions invalidate non-conforming assessments, while ad hoc nil pricing of intra-group services fails.
    September 1, 2026   Case Laws Income Tax
    Electronic service of DRP directions triggers assessment limitation, making a belated final assessment time-barred and beyond jurisdiction.
    September 1, 2026   Case Laws Income Tax
    TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
    September 1, 2026   Case Laws Income Tax
    Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
    September 1, 2026   Case Laws Income Tax
    Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
    September 1, 2026   Case Laws Income Tax
    Misreporting penalties require proven statutory defaults, not merely transfer-pricing adjustments caused by competing benchmarking and comparability m...
    September 1, 2026   Case Laws Income Tax
    Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
    September 1, 2026   Case Laws Income Tax
    Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
    September 1, 2026   Case Laws Income Tax
    TDS liability on foreign-agent commission requires verification of payment figures and Indian taxable presence before fresh adjudication.
    September 1, 2026   Case Laws Income Tax
    Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
    September 1, 2026   Case Laws Income Tax
    Maintainability of revision-order appeals depends on grounds showing a grievance against revision, otherwise dismissal follows independently.
    September 1, 2026   Case Laws Customs
    Related-party customs valuation requires objective doubt, while royalties not conditional on imported goods' sale remain excluded.
    September 1, 2026   Case Laws Customs
    Specific drugs-and-medicines classification gives eligible bulk drugs and APIs concessional IGST treatment despite chemical tariff classification.
    September 1, 2026   Case Laws Customs
    Specific drug-rate entry covers imported APIs and bulk drugs, overriding general chemical chapter entries for concessional IGST treatment.
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September 1, 2026   Case Laws Income Tax
Transfer-pricing benchmarking requires proven COVID costs, consistent TNMM classifications, and reliable internal CUP comparability before adjustments.
September 1, 2026   Case Laws Income Tax
Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjustment.
September 1, 2026   Case Laws Income Tax
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitability.
September 1, 2026   Case Laws Income Tax
Transfer-pricing comparability requires aligned related-party exposure, ownership profile, revenue model and sourcing-support functions to prevent distorted margins in benchmark analysis.
September 1, 2026   Case Laws Income Tax
Assessment jurisdiction requires valid statutory transfer and timely scrutiny notice; administrative reassignment cannot sustain proceedings.
September 1, 2026   Case Laws Income Tax
TDS on statutory market fees and pass-through procurement payments did not trigger contract withholding disallowance.
September 1, 2026   Case Laws Income Tax
Binding Dispute Resolution Panel directions invalidate non-conforming assessments, while ad hoc nil pricing of intra-group services fails.
September 1, 2026   Case Laws Income Tax
Electronic service of DRP directions triggers assessment limitation, making a belated final assessment time-barred and beyond jurisdiction.
September 1, 2026   Case Laws Income Tax
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export receipts.
September 1, 2026   Case Laws Income Tax
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notional-interest adjustment.
September 1, 2026   Case Laws Income Tax
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and margin findings.
September 1, 2026   Case Laws Income Tax
Misreporting penalties require proven statutory defaults, not merely transfer-pricing adjustments caused by competing benchmarking and comparability methodologies.
September 1, 2026   Case Laws Income Tax
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the statutory limit.
September 1, 2026   Case Laws Income Tax
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings were quashed.
September 1, 2026   Case Laws Income Tax
TDS liability on foreign-agent commission requires verification of payment figures and Indian taxable presence before fresh adjudication.
September 1, 2026   Case Laws Income Tax
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-capital adjustments require verification.
September 1, 2026   Case Laws Income Tax
Maintainability of revision-order appeals depends on grounds showing a grievance against revision, otherwise dismissal follows independently.
September 1, 2026   Case Laws Customs
Related-party customs valuation requires objective doubt, while royalties not conditional on imported goods' sale remain excluded.
September 1, 2026   Case Laws Customs
Specific drugs-and-medicines classification gives eligible bulk drugs and APIs concessional IGST treatment despite chemical tariff classification.
September 1, 2026   Case Laws Customs
Specific drug-rate entry covers imported APIs and bulk drugs, overriding general chemical chapter entries for concessional IGST treatment.

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Customs

Applying the General Rules of Interpretation and Section XVI...

Principal Function Test confirms GPS radio navigational character, classifying the device as a radio navigational aid.

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Customs March 12, 2026 Case Laws AAR
Applying the General Rules of Interpretation and Section XVI Note 3, the principal-function test was used to classify a composite tracking device composed of a GPS receiver, sensors and a modem. The device's dominant commercial purpose and essential character derive from GPS-based determination of geographic position; sensors and modem were held ancillary because they supply supplementary metrics and relay GPS-derived data. Accordingly, the device is classifiable as radio navigational aid apparatus and assigned to tariff subheading 8526 91 90 as other radio navigational aid apparatus.
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Acts Income Tax
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