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    June 4, 2026   Case Laws Income Tax
    Liberal condonation for co-operative societies' delayed returns under CBDT hardship circulars, rejecting hyper-technical refusal of relief.
    June 4, 2026   Case Laws Income Tax
    Section 53A cannot confer ownership for depreciation; writ challenge also failed on natural justice and was sent to appeal.
    June 4, 2026   Case Laws Income Tax
    Unexplained investment additions limited to estimated income where supporting records partly substantiate the source of funds
    June 4, 2026   Case Laws Income Tax
    Bank deposits as business turnover cannot be taxed again as unexplained income where presumptive profit was already offered.
    June 4, 2026   Case Laws Income Tax
    Transfer pricing benchmarking must follow segmental profitability and FAR-comparable exporters, with the statutory tolerance band applied.
    June 4, 2026   Case Laws Income Tax
    Capital gains computation must allow fair market value substitution and proper scrutiny of valuation claims before taxing sale proceeds.
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    Household withdrawals, unexplained creditors, and freight TDS disallowance were each tested on evidence and sustained or deleted accordingly.
    June 4, 2026   Case Laws Income Tax
    Related-party slump loss and compensation receipts taxed as revenue while own-fund interest claims and section 14A relief were upheld
    June 4, 2026   Case Laws Income Tax
    Typographical error in employer TAN may be corrected to secure TDS credit where substantive entitlement exists.
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    Cessation of liability under Section 41(1) fails where AOP funds are received personally and introduced as capital.
    June 4, 2026   Case Laws Income Tax
    Technical misdescription of deduction provision cannot defeat genuine donation relief where payment to an approved institution is otherwise eligible.
    June 4, 2026   Case Laws Income Tax
    Co-terminus appellate powers and mandatory reassessment notice govern remand and deletion of additions for lack of section 143(2) notice.
    June 4, 2026   Case Laws Income Tax
    Revenue-neutral timing of interest deduction under mercantile accounting defeats disallowance of genuine business expenditure.
    June 4, 2026   Case Laws Income Tax
    Section 10(46) exemption covers regulatory and incidental receipts; accounting as prior period income does not change exempt character.
    June 4, 2026   Case Laws Income Tax
    Opening work-in-progress treated as prior-period investment cannot be taxed as unexplained investment in the current year.
    June 4, 2026   Case Laws Income Tax
    Discretionary penalty under the Black Money Act cannot stand for bona fide non-disclosure of foreign ESOP shares already taxed
    June 4, 2026   Case Laws Benami Property
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    June 4, 2026   Case Laws Benami Property
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    Declared value for used garments needs reliable comparables; restricted second-hand imports without licence may still attract confiscation and moderat...
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June 4, 2026   Case Laws Income Tax
Liberal condonation for co-operative societies' delayed returns under CBDT hardship circulars, rejecting hyper-technical refusal of relief.
June 4, 2026   Case Laws Income Tax
Section 53A cannot confer ownership for depreciation; writ challenge also failed on natural justice and was sent to appeal.
June 4, 2026   Case Laws Income Tax
Unexplained investment additions limited to estimated income where supporting records partly substantiate the source of funds
June 4, 2026   Case Laws Income Tax
Bank deposits as business turnover cannot be taxed again as unexplained income where presumptive profit was already offered.
June 4, 2026   Case Laws Income Tax
Transfer pricing benchmarking must follow segmental profitability and FAR-comparable exporters, with the statutory tolerance band applied.
June 4, 2026   Case Laws Income Tax
Capital gains computation must allow fair market value substitution and proper scrutiny of valuation claims before taxing sale proceeds.
June 4, 2026   Case Laws Income Tax
Household withdrawals, unexplained creditors, and freight TDS disallowance were each tested on evidence and sustained or deleted accordingly.
June 4, 2026   Case Laws Income Tax
Related-party slump loss and compensation receipts taxed as revenue while own-fund interest claims and section 14A relief were upheld
June 4, 2026   Case Laws Income Tax
Typographical error in employer TAN may be corrected to secure TDS credit where substantive entitlement exists.
June 4, 2026   Case Laws Income Tax
Cessation of liability under Section 41(1) fails where AOP funds are received personally and introduced as capital.
June 4, 2026   Case Laws Income Tax
Technical misdescription of deduction provision cannot defeat genuine donation relief where payment to an approved institution is otherwise eligible.
June 4, 2026   Case Laws Income Tax
Co-terminus appellate powers and mandatory reassessment notice govern remand and deletion of additions for lack of section 143(2) notice.
June 4, 2026   Case Laws Income Tax
Revenue-neutral timing of interest deduction under mercantile accounting defeats disallowance of genuine business expenditure.
June 4, 2026   Case Laws Income Tax
Section 10(46) exemption covers regulatory and incidental receipts; accounting as prior period income does not change exempt character.
June 4, 2026   Case Laws Income Tax
Opening work-in-progress treated as prior-period investment cannot be taxed as unexplained investment in the current year.
June 4, 2026   Case Laws Income Tax
Discretionary penalty under the Black Money Act cannot stand for bona fide non-disclosure of foreign ESOP shares already taxed
June 4, 2026   Case Laws Benami Property
Review order restoring appeals is not independently appealable where the Tribunal acts on reserved liberty and binding precedent.
June 4, 2026   Case Laws Benami Property
Benami transaction tracing through money trail sustained provisional attachment of a vehicle linked to land compensation funds.
June 4, 2026   Case Laws Customs
SEZ procurement and diversion findings set aside after inadmissible statements, weak data reliance, and burden-of-proof errors.
June 4, 2026   Case Laws Customs
Declared value for used garments needs reliable comparables; restricted second-hand imports without licence may still attract confiscation and moderate penalties.

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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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