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    April 13, 2026   Case LawsGST
    ITC mismatch reconciliation required before adverse GST adjudication; demand set aside and matter remanded for fresh consideration
    April 13, 2026   Case LawsGST
    Vague show cause notice and denial of effective hearing led to quashing of the assessment order and remand
    April 13, 2026   Case LawsIncome Tax
    Reassessment after 143(1) processing and project-linked interest held not taxable as income from other sources.
    April 13, 2026   Case LawsIncome Tax
    Commercial expediency, bad debt write-off, and actual payment deductions require proper factual verification before relief is granted.
    April 13, 2026   Case LawsIncome Tax
    Replacement of machinery and current repairs test require independent scrutiny; revenue-or-capital issue remitted for fresh adjudication.
    April 13, 2026   Case LawsIncome Tax
    Law enforcement agency scope under CBDT circulars interpreted broadly; DGCEI included and rectification matter remanded.
    April 13, 2026   Case LawsIncome Tax
    Genuine purchase evidence and bank-financed assets led ITAT to delete bogus purchase additions.
    April 13, 2026   Case LawsMoney Laundering
    Reverse burden of proof under the PMLA sustained freezing of accounts and retention of seized material.
    April 13, 2026   Case LawsIndian Laws
    Arbitration joinder and appeal maintainability: tribunal's protective order allowing trustee participation was upheld.
    April 13, 2026   Case LawsIncome Tax
    Trademark depreciation and section 14A adjustments: ITAT applies consistency, independent book-profit computation, and no disallowance without exempt ...
    April 13, 2026   Case LawsIncome Tax
    Genuineness of purchases and reassessment notice defects led to deletion of bogus purchase addition and reopening challenge
    April 13, 2026   Case LawsIncome Tax
    Belated Form 10B filing treated as a procedural lapse, allowing exemption claims under sections 11 and 12 to proceed.
    April 13, 2026   Case LawsIncome Tax
    Rebuttable search presumptions and corroboration standards shaped deletion of unsubstantiated additions, while rental income and limited profit estima...
    April 13, 2026   Case LawsIncome Tax
    Accrual basis deduction for member deposit interest upheld; section 43B(e) does not apply and section 80P relief continues.
    April 13, 2026   Case LawsIncome Tax
    Long-term finance deductions upheld for loan-linked fees, pre-closed loans, exempt-income investments and CSR donations.
    April 13, 2026   Case LawsBenami Property
    Benami transaction proof upheld where control, fund trails, and corroborated statements established companies as fronts for real ownership.
    April 13, 2026   Case LawsCustoms
    Minimum Import Price for roasted areca nut upheld as a lawful non-tariff safeguard under trade law framework.
    April 13, 2026   Case LawsCustoms
    Motor vehicle air-conditioning compressors fall under Heading 8708; bona fide classification dispute defeats Section 74 penalty.
    April 13, 2026   Case LawsCustoms
    End-use compliance under customs exemption notifications can outweigh procedural lapses when substantive eligibility is established.
    April 13, 2026   Case LawsCustoms
    MEIS scrip validity and limitation bar customs recovery where departmental knowledge and uncancelled DGFT proceedings exist.
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    April 13, 2026   Case Laws GST
    ITC mismatch reconciliation required before adverse GST adjudication; demand set aside and matter remanded for fresh consideration
    April 13, 2026   Case Laws GST
    Vague show cause notice and denial of effective hearing led to quashing of the assessment order and remand
    April 13, 2026   Case Laws Income Tax
    Reassessment after 143(1) processing and project-linked interest held not taxable as income from other sources.
    April 13, 2026   Case Laws Income Tax
    Commercial expediency, bad debt write-off, and actual payment deductions require proper factual verification before relief is granted.
    April 13, 2026   Case Laws Income Tax
    Replacement of machinery and current repairs test require independent scrutiny; revenue-or-capital issue remitted for fresh adjudication.
    April 13, 2026   Case Laws Income Tax
    Law enforcement agency scope under CBDT circulars interpreted broadly; DGCEI included and rectification matter remanded.
    April 13, 2026   Case Laws Income Tax
    Genuine purchase evidence and bank-financed assets led ITAT to delete bogus purchase additions.
    April 13, 2026   Case Laws Money Laundering
    Reverse burden of proof under the PMLA sustained freezing of accounts and retention of seized material.
    April 13, 2026   Case Laws Indian Laws
    Arbitration joinder and appeal maintainability: tribunal's protective order allowing trustee participation was upheld.
    April 13, 2026   Case Laws Income Tax
    Trademark depreciation and section 14A adjustments: ITAT applies consistency, independent book-profit computation, and no disallowance without exempt income.
    April 13, 2026   Case Laws Income Tax
    Genuineness of purchases and reassessment notice defects led to deletion of bogus purchase addition and reopening challenge
    April 13, 2026   Case Laws Income Tax
    Belated Form 10B filing treated as a procedural lapse, allowing exemption claims under sections 11 and 12 to proceed.
    April 13, 2026   Case Laws Income Tax
    Rebuttable search presumptions and corroboration standards shaped deletion of unsubstantiated additions, while rental income and limited profit estimates were sustained.
    April 13, 2026   Case Laws Income Tax
    Accrual basis deduction for member deposit interest upheld; section 43B(e) does not apply and section 80P relief continues.
    April 13, 2026   Case Laws Income Tax
    Long-term finance deductions upheld for loan-linked fees, pre-closed loans, exempt-income investments and CSR donations.
    April 13, 2026   Case Laws Benami Property
    Benami transaction proof upheld where control, fund trails, and corroborated statements established companies as fronts for real ownership.
    April 13, 2026   Case Laws Customs
    Minimum Import Price for roasted areca nut upheld as a lawful non-tariff safeguard under trade law framework.
    April 13, 2026   Case Laws Customs
    Motor vehicle air-conditioning compressors fall under Heading 8708; bona fide classification dispute defeats Section 74 penalty.
    April 13, 2026   Case Laws Customs
    End-use compliance under customs exemption notifications can outweigh procedural lapses when substantive eligibility is established.
    April 13, 2026   Case Laws Customs
    MEIS scrip validity and limitation bar customs recovery where departmental knowledge and uncancelled DGFT proceedings exist.

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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 TaxMarch 27, 2026Case LawsAT
      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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