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    April 11, 2026   Case LawsIncome Tax
    Revised return can replace the original return and permit a change from SLM to WDV depreciation when omissions are bona fide.
    April 11, 2026   Case LawsIncome Tax
    TDS on discounted lottery ticket sales is not commission where the transaction is principal-to-principal and no payment is credited.
    April 11, 2026   Case LawsIncome Tax
    Reassessment cannot rest on unverified third-party material without a direct nexus to the assessee; reopening quashed.
    April 11, 2026   Case LawsIncome Tax
    Natural justice in faceless assessment: truncated video-conference notice and denial of reasonable hearing led to remand.
    April 11, 2026   Case LawsIncome Tax
    Penalty for concealed capital gains upheld where exemption claim lacked bona fide basis and return showed inaccurate particulars.
    April 11, 2026   Case LawsIncome Tax
    Co-operative credit society deduction on bank deposit interest upheld where funds were business funds and income remained attributable to member credi...
    April 11, 2026   Case LawsIncome Tax
    Valuation Officer reference cannot be used for reopening assessment when books are not rejected and no defects are found.
    April 11, 2026   Case LawsIncome Tax
    Working capital adjustment claims need authenticated supporting documents; fresh consideration ordered after proper compliance and hearing.
    April 11, 2026   Case LawsIncome Tax
    Penny stock capital gains treated as accommodation entries where human probabilities showed an unexplained income conversion scheme.
    April 11, 2026   Case LawsIncome Tax
    TDS credit belongs only to the person taxed on the related income; wrong PAN deduction cannot be claimed by a commission agent.
    April 11, 2026   Case LawsIncome Tax
    Clerical loss mismatch and encroachment compensation accepted as cost of improvement in capital gains computation.
    April 11, 2026   Case LawsIncome Tax
    Telescoping of undisclosed on-money receipts against demonetisation cash deposits allowed partly, with normal tax rates and section 68 relief.
    April 11, 2026   Case LawsIncome Tax
    Transfer pricing benchmarking and receivables adjustments remanded: segmental financials need proper scrutiny, and foreign-currency interest must trac...
    April 11, 2026   Case LawsIncome Tax
    Speaking order on reopening objections is mandatory; reassessment annulled when the objections were not disposed of first.
    April 11, 2026   Case LawsIncome Tax
    Pecuniary jurisdiction under CBDT instruction invalidated notice issued by officer lacking competence, quashing the assessment.
    April 11, 2026   Case LawsIncome Tax
    Fair market rent and related-party salary claims were accepted where evidence showed reasonable rent and genuine business services.
    April 11, 2026   Case LawsBenami Property
    Recall of ex parte orders requires sufficient cause for absence; repeated non-appearance and delayed additional material defeated recall.
    April 11, 2026   Case LawsCustoms
    Non-speaking provisional release order quashed for failure to address customs objections and BIS certificate concerns.
    April 11, 2026   Case LawsCustoms
    Refund of withdrawn provisional anti-dumping duty cannot be denied on unjust enrichment grounds under the Anti-Dumping Rules.
    April 11, 2026   Case LawsCustoms
    Essential character of multifunctional wheelchairs governed classification and exemption despite an added toileting feature.
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    April 11, 2026   Case Laws Income Tax
    Revised return can replace the original return and permit a change from SLM to WDV depreciation when omissions are bona fide.
    April 11, 2026   Case Laws Income Tax
    TDS on discounted lottery ticket sales is not commission where the transaction is principal-to-principal and no payment is credited.
    April 11, 2026   Case Laws Income Tax
    Reassessment cannot rest on unverified third-party material without a direct nexus to the assessee; reopening quashed.
    April 11, 2026   Case Laws Income Tax
    Natural justice in faceless assessment: truncated video-conference notice and denial of reasonable hearing led to remand.
    April 11, 2026   Case Laws Income Tax
    Penalty for concealed capital gains upheld where exemption claim lacked bona fide basis and return showed inaccurate particulars.
    April 11, 2026   Case Laws Income Tax
    Co-operative credit society deduction on bank deposit interest upheld where funds were business funds and income remained attributable to member credit activities.
    April 11, 2026   Case Laws Income Tax
    Valuation Officer reference cannot be used for reopening assessment when books are not rejected and no defects are found.
    April 11, 2026   Case Laws Income Tax
    Working capital adjustment claims need authenticated supporting documents; fresh consideration ordered after proper compliance and hearing.
    April 11, 2026   Case Laws Income Tax
    Penny stock capital gains treated as accommodation entries where human probabilities showed an unexplained income conversion scheme.
    April 11, 2026   Case Laws Income Tax
    TDS credit belongs only to the person taxed on the related income; wrong PAN deduction cannot be claimed by a commission agent.
    April 11, 2026   Case Laws Income Tax
    Clerical loss mismatch and encroachment compensation accepted as cost of improvement in capital gains computation.
    April 11, 2026   Case Laws Income Tax
    Telescoping of undisclosed on-money receipts against demonetisation cash deposits allowed partly, with normal tax rates and section 68 relief.
    April 11, 2026   Case Laws Income Tax
    Transfer pricing benchmarking and receivables adjustments remanded: segmental financials need proper scrutiny, and foreign-currency interest must track LIBOR.
    April 11, 2026   Case Laws Income Tax
    Speaking order on reopening objections is mandatory; reassessment annulled when the objections were not disposed of first.
    April 11, 2026   Case Laws Income Tax
    Pecuniary jurisdiction under CBDT instruction invalidated notice issued by officer lacking competence, quashing the assessment.
    April 11, 2026   Case Laws Income Tax
    Fair market rent and related-party salary claims were accepted where evidence showed reasonable rent and genuine business services.
    April 11, 2026   Case Laws Benami Property
    Recall of ex parte orders requires sufficient cause for absence; repeated non-appearance and delayed additional material defeated recall.
    April 11, 2026   Case Laws Customs
    Non-speaking provisional release order quashed for failure to address customs objections and BIS certificate concerns.
    April 11, 2026   Case Laws Customs
    Refund of withdrawn provisional anti-dumping duty cannot be denied on unjust enrichment grounds under the Anti-Dumping Rules.
    April 11, 2026   Case Laws Customs
    Essential character of multifunctional wheelchairs governed classification and exemption despite an added toileting feature.

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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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