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    May 30, 2026   Case Laws Income Tax
    Reasonable cause for notice non-compliance defeated penalty where medical incapacity explained the default.
    May 30, 2026   Case Laws Income Tax
    Amortisation, exempt-income disallowance and intangible asset depreciation are analysed through contractual rights and own-funds principles.
    May 30, 2026   Case Laws Income Tax
    Retrospective cancellation of charitable registration under section 12AB(4) was unsustainable; related-party benefit allegations did not prove nongenu...
    May 30, 2026   Case Laws Income Tax
    Penalty notice vagueness under section 270A invalidates proceedings when the precise limb of charge is not specified.
    May 30, 2026   Case Laws Income Tax
    Dominant object test: Arabic and Islamic instruction treated as education, not a religious trust, restoring tax approvals.
    May 30, 2026   Case Laws Income Tax
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    Monetary jurisdiction for reassessment notice fails where ACIT issues section 148 notice beyond prescribed corporate case limits.
    May 30, 2026   Case Laws Customs
    Mandatory ninety-day show cause timeline under Customs Brokers Licensing Regulations breaches vitiate the notice and inquiry report.
    May 30, 2026   Case Laws Customs
    User test in classification of imported solar cells leads to remand for fresh determination as satellite parts.
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    May 30, 2026   Case Laws Law of Competition
    Merger control notice and disclosure rules: Supreme Court limits penalties, rejects reopening of approved combination, and sets aside adverse findings...
    May 30, 2026   Case Laws Money Laundering
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    May 30, 2026   Case Laws Indian Laws
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    May 29, 2026   Notifications Money Laundering
    Aadhaar authentication expanded for five SEBI-regulated entities under the money-laundering compliance framework.
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    May 29, 2026   Circulars GST - States
    GST departmental appeal limits and Zonal Law Committees updated for review, appeal selection, and uniform appellate practice.
    May 29, 2026   Circulars GST - States
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May 30, 2026   Case Laws Income Tax
Reasonable cause for notice non-compliance defeated penalty where medical incapacity explained the default.
May 30, 2026   Case Laws Income Tax
Amortisation, exempt-income disallowance and intangible asset depreciation are analysed through contractual rights and own-funds principles.
May 30, 2026   Case Laws Income Tax
Retrospective cancellation of charitable registration under section 12AB(4) was unsustainable; related-party benefit allegations did not prove nongenuine activity.
May 30, 2026   Case Laws Income Tax
Penalty notice vagueness under section 270A invalidates proceedings when the precise limb of charge is not specified.
May 30, 2026   Case Laws Income Tax
Dominant object test: Arabic and Islamic instruction treated as education, not a religious trust, restoring tax approvals.
May 30, 2026   Case Laws Income Tax
Concessional tax regime under section 115BAA prevails, with MAT under section 115JB held inapplicable.
May 30, 2026   Case Laws Income Tax
Monetary jurisdiction for reassessment notice fails where ACIT issues section 148 notice beyond prescribed corporate case limits.
May 30, 2026   Case Laws Customs
Mandatory ninety-day show cause timeline under Customs Brokers Licensing Regulations breaches vitiate the notice and inquiry report.
May 30, 2026   Case Laws Customs
User test in classification of imported solar cells leads to remand for fresh determination as satellite parts.
May 30, 2026   Case Laws Customs
Documentary verification for shipping bill conversion prevailed, and absence of physical examination was not treated as a disqualifying factor.
May 30, 2026   Case Laws Customs
Interpretation of "including" in LED lighting exemption upheld, extending concessional tax benefit to imported fixtures.
May 30, 2026   Case Laws IBC
CoC-approved resolution process binds the applicant, justifies earnest money forfeiture, and supports liquidation on commercial wisdom.
May 30, 2026   Case Laws Law of Competition
Merger control notice and disclosure rules: Supreme Court limits penalties, rejects reopening of approved combination, and sets aside adverse findings.
May 30, 2026   Case Laws Money Laundering
Equivalent-value attachment under PMLA sustained where properties were bought during criminal activity and no lawful source of funds was shown.
May 30, 2026   Case Laws Indian Laws
Cheque dishonour proceedings are predominantly criminal, but IBC moratorium may still shield compensatory recovery in insolvency.
May 30, 2026   Case Laws Indian Laws
Arbitral award enforcement against non-signatories upheld where they were treated as persons claiming under the award-debtor SPV.
May 29, 2026   Notifications Money Laundering
Aadhaar authentication expanded for five SEBI-regulated entities under the money-laundering compliance framework.
May 29, 2026   Notifications Money Laundering
Aadhaar authentication permission granted for anti-money laundering compliance under the statutory framework
May 29, 2026   Circulars GST - States
GST departmental appeal limits and Zonal Law Committees updated for review, appeal selection, and uniform appellate practice.
May 29, 2026   Circulars GST - States
E-way bill threshold clarified for intra-State goods movement; job work transfers remain exempt from generation requirement.

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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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