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    Taxability of contractual receipts follows the accounting method and Form 26AS reflection, ITAT upholds addition.
    Penalty for non-compliance with notice set aside where adjournments were sought and details were later furnished in scrutiny assessment.
    Transfer pricing comparables excluded after remand failure, with arm's length price adjustment recomputed for software services.
    Arm's length pricing of captive power transfers: industrial tariff accepted as the benchmark, and the transfer pricing adjustment was deleted.
    Plausible explanation for offering income and paying tax led ITAT to delete penalty for alleged cash receipts.
    Real income and tax credit principles led to deletion of expense disallowance and verification of self-assessment tax credit.
    Timing mismatch in income recognition requires verification whether receipts were already taxed in an earlier year; matter remitted for fresh examinat...
    Embedded profit in on-money receipts taxed at 10%, with income recognised on sale deed execution, not cash receipt.
    Surcharge on private discretionary trusts: ITAT applies Finance Act slab rates and accepts 15% surcharge instead of 25%.
    Provisional release conditions: bank guarantee for seized goods held arbitrary, while appeal maintainability was upheld.
    Ore-to-concentrate conversion defeats CVD exemption where imported manganese has undergone washing, waste removal and sizing.
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    Customs Broker due diligence obligations narrowly construed; revocation and penalty set aside for lack of proof of regulatory breach.
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    Export proceeds realisation and director liability under FEMA were upheld for failure to ship goods and recover outstanding exports.
    Proof of import through Bills of Entry failed on inadequate high sea sale evidence, sustaining remittance contravention
    Electronic evidence and retracted statements under FEMA upheld, but penalties were reduced for excessive quantum.
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      Income-tax Rules, 2026 prescribe comprehensive operational...

      Fair market value and income attribution rules set methodology for valuation, transfer pricing and taxation of cross-border transfers.

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      Income TaxMarch 21, 2026Notifications
      Income-tax Rules, 2026 prescribe comprehensive operational measures: definitions and commencement; domestic dividend declaration and payment requirements; conditions and procedure for notification of recognised stock exchanges; valuation and fair market value methodologies for shares, firms and foreign entities and formulae for attributing income to assets in India; procedures for notification of zero coupon bonds and associated investment and reporting conditions; computation rules for period of holding and capital gains; residence and stay computation for seafarers; extensive transfer pricing framework including comparability, most-appropriate-method selection, dataset and arm's-length range rules, safe-harbour parameters and advance pricing agreement procedures; perquisites valuation, deduction, audit and reporting forms and multiple sectoral procedural provisions and prescribed forms.

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      ActsIncome Tax