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    August 29, 2026   Case Laws Income Tax
    Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
    August 29, 2026   Case Laws Income Tax
    TDS-default expenditure requires proof of prior-year disallowance; unnotified entities cannot claim exemption despite pending writ proceedings.
    August 29, 2026   Case Laws Income Tax
    Double addition of goodwill cannot stand where its book write-off was already added back; depreciation disallowance remained.
    August 29, 2026   Case Laws Income Tax
    Search-related assessment framework governs post-search proceedings, while evidentiary burdens shape loan, cash, and transfer-pricing adjustments.
    August 29, 2026   Case Laws Income Tax
    Trade discount characterisation prevails over tax statement labels when invoice reconciliation establishes the receipts' true nature.
    August 29, 2026   Case Laws Income Tax
    Interest on enhanced compensation remains taxable, while the statutory half deduction must reduce taxable income.
    August 29, 2026   Case Laws Customs
    Reasonable Time for Drawback Recovery invalidates delayed recovery and bank-account attachment where fraud or suppression is not alleged.
    August 29, 2026   Case Laws Customs
    Customs reclassification requires technical evidence; unsupported rejection of mixed-fibre fabric classification cannot sustain duty, interest or pena...
    August 29, 2026   Case Laws Companies Law
    Territorial jurisdiction under Article 226(2) requires substantial nexus and forum convenience, directing the investigation challenge to Mumbai.
    August 29, 2026   Case Laws IBC
    Resolution-plan tax waivers do not cover GST liabilities arising after the plan's specified cut-off, requiring statutory appeal and pre-deposit.
    August 29, 2026   Case Laws Money Laundering
    PMLA provisional attachment challenges must ordinarily follow statutory remedies where no jurisdictional or natural justice exception is established.
    August 29, 2026   Case Laws Money Laundering
    Bank account freezing requires statutory authority; anti-money-laundering compliance and KYC monitoring do not permit unilateral indefinite restrictio...
    August 29, 2026   Case Laws Service Tax
    Best-judgment service tax assessments require verified records, while limitation and duplicate recovery constraints govern reassessment.
    August 29, 2026   Case Laws Service Tax
    Wet leasing of compressor equipment remains taxable as supply of tangible goods service where control stays with the owner.
    August 29, 2026   Case Laws Central Excise
    CENVAT credit on contractor-procured capital goods remains available when factory receipt supports captive manufacturing installation.
    August 28, 2026   Notifications Customs
    Customs tariff valuation for edible oils, brass scrap, areca nuts, gold and silver continues under substituted valuation tables.
    August 28, 2026   Circulars DGFT
    Pre-shipment inspection certificates must be issued on inspection date, with automated inspector verification and expanded digital evidence uploads.
    August 28, 2026   Case Laws GST
    Regular bail in alleged fake-invoice input tax credit prosecution follows custody, documentary evidence, and low interference risk.
    August 28, 2026   Case Laws GST
    Ex parte GST adjudication may be reopened to restore a taxpayer's opportunity to reply, submit evidence, and be heard.
    August 28, 2026   Case Laws GST
    Composite GST assessment orders for distinct tax periods require separate notices and hearings before any fresh proceedings.
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August 29, 2026   Case Laws Income Tax
Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and margin issues.
August 29, 2026   Case Laws Income Tax
TDS-default expenditure requires proof of prior-year disallowance; unnotified entities cannot claim exemption despite pending writ proceedings.
August 29, 2026   Case Laws Income Tax
Double addition of goodwill cannot stand where its book write-off was already added back; depreciation disallowance remained.
August 29, 2026   Case Laws Income Tax
Search-related assessment framework governs post-search proceedings, while evidentiary burdens shape loan, cash, and transfer-pricing adjustments.
August 29, 2026   Case Laws Income Tax
Trade discount characterisation prevails over tax statement labels when invoice reconciliation establishes the receipts' true nature.
August 29, 2026   Case Laws Income Tax
Interest on enhanced compensation remains taxable, while the statutory half deduction must reduce taxable income.
August 29, 2026   Case Laws Customs
Reasonable Time for Drawback Recovery invalidates delayed recovery and bank-account attachment where fraud or suppression is not alleged.
August 29, 2026   Case Laws Customs
Customs reclassification requires technical evidence; unsupported rejection of mixed-fibre fabric classification cannot sustain duty, interest or penalties.
August 29, 2026   Case Laws Companies Law
Territorial jurisdiction under Article 226(2) requires substantial nexus and forum convenience, directing the investigation challenge to Mumbai.
August 29, 2026   Case Laws IBC
Resolution-plan tax waivers do not cover GST liabilities arising after the plan's specified cut-off, requiring statutory appeal and pre-deposit.
August 29, 2026   Case Laws Money Laundering
PMLA provisional attachment challenges must ordinarily follow statutory remedies where no jurisdictional or natural justice exception is established.
August 29, 2026   Case Laws Money Laundering
Bank account freezing requires statutory authority; anti-money-laundering compliance and KYC monitoring do not permit unilateral indefinite restrictions.
August 29, 2026   Case Laws Service Tax
Best-judgment service tax assessments require verified records, while limitation and duplicate recovery constraints govern reassessment.
August 29, 2026   Case Laws Service Tax
Wet leasing of compressor equipment remains taxable as supply of tangible goods service where control stays with the owner.
August 29, 2026   Case Laws Central Excise
CENVAT credit on contractor-procured capital goods remains available when factory receipt supports captive manufacturing installation.
August 28, 2026   Notifications Customs
Customs tariff valuation for edible oils, brass scrap, areca nuts, gold and silver continues under substituted valuation tables.
August 28, 2026   Circulars DGFT
Pre-shipment inspection certificates must be issued on inspection date, with automated inspector verification and expanded digital evidence uploads.
August 28, 2026   Case Laws GST
Regular bail in alleged fake-invoice input tax credit prosecution follows custody, documentary evidence, and low interference risk.
August 28, 2026   Case Laws GST
Ex parte GST adjudication may be reopened to restore a taxpayer's opportunity to reply, submit evidence, and be heard.
August 28, 2026   Case Laws GST
Composite GST assessment orders for distinct tax periods require separate notices and hearings before any fresh proceedings.

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

Persistent Systems Ltd. was rejected as a comparable under TNMM...

TNMM comparability and foreign tax credit verification shape software transfer pricing relief and working capital adjustment

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Income Tax March 27, 2026 Case Laws AT
Persistent Systems Ltd. was rejected as a comparable under TNMM because the assessee was a captive software development service provider, while Persistent operated an IP-led product development model with product, licensing and other mixed revenues, different risk profile, and no segmental break-up. Akshay Software Technologies Ltd., Cigniti Technologies Ltd. and Evoke Technologies Pvt. Ltd. were accepted as comparables because their software-related activities, quantitative filters and reliable financial data supported inclusion. Foreign tax credit was restored for verification of supporting documents, including Form 67, withholding proof and Indian taxability of the corresponding income, and working capital adjustment was directed after verification in accordance with law. Both appeals were partly allowed.
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Acts Income Tax
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