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    April 9, 2026   CircularsSEBI
    Lock-in of pledged shares streamlined through non-transferable depository tagging and issuer disclosures under the ICDR framework
    April 9, 2026   CircularsCustoms
    SCMTR transition extended with electronic declaration compliance, pending message integration, and stakeholder outreach for smooth implementation.
    April 9, 2026   CircularsCustoms
    SCMTR transitional period extended; stakeholders must file correct electronic declarations while outreach programmes support compliance.
    April 9, 2026   Case LawsGST
    GST detention proceedings require timely seizure action, ownership determination from documents, and allowance of advocate representation.
    April 9, 2026   Case LawsGST
    Personal hearing is mandatory before confiscation under Section 130; order quashed for breach of natural justice.
    April 9, 2026   Case LawsGST
    Conditional restoration of GST registration granted where cancellation was only for non-filing of returns, without tax evasion allegations.
    April 9, 2026   Case LawsGST
    Premature writ challenge to ITC blockage notices deferred until replies are heard and factual issues are adjudicated
    April 9, 2026   Case LawsGST
    Parallel tax enforcement barred where duplicate proceedings led to quashing of bank account attachment and restoration of business access.
    April 9, 2026   Case LawsGST
    Transitional credit correction in revised TRAN-1 and TRAN-2 allowed; writ maintainable, assessment quashed, matter remitted.
    April 9, 2026   Case LawsGST
    Detention and confiscation in transit require section 129 to run its course before section 130 confiscation can be invoked.
    April 9, 2026   Case LawsGST
    Writ maintainability and GST rectification appeals: parallel writ relief barred, statutory appeal under Section 107 available
    April 9, 2026   Case LawsIncome Tax
    Revisional power in block assessment upheld, undisclosed search income sustained, freight suppression addition restored, accrued lorry hire liability ...
    April 9, 2026   Case LawsIncome Tax
    Income recognition, energy tax, accrued liability and computer depreciation issues were all resolved against the Department.
    April 9, 2026   Case LawsIncome Tax
    Procedural lapse cannot defeat concessional tax benefit where eligibility is undisputed and delay is short and bona fide.
    April 9, 2026   Case LawsIncome Tax
    Section 170A limits post-amalgamation assessment to modification only where the assessment was already completed.
    April 9, 2026   Case LawsIncome Tax
    Book profit treatment for bad debts and directory audit-report filing shaped the outcome on deduction claims.
    April 9, 2026   Case LawsIncome Tax
    Bona fide treaty relief claim defeats penalty where income was disclosed and no concealment or inaccurate particulars were proved.
    April 9, 2026   Case LawsIncome Tax
    Prior-period expenditure may be considered in the correct assessment year when genuineness is undisputed and revised computation is filed.
    April 9, 2026   Case LawsIncome Tax
    Commercial expediency and rectification limits upheld as interest deduction was allowed and no apparent mistake was found.
    April 9, 2026   Case LawsIncome Tax
    Reassessment and fee-for-technical-services classification: reopening upheld, but certain reimbursements and mobilization charges fell outside treaty ...
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    April 9, 2026   Circulars SEBI
    Lock-in of pledged shares streamlined through non-transferable depository tagging and issuer disclosures under the ICDR framework
    April 9, 2026   Circulars Customs
    SCMTR transition extended with electronic declaration compliance, pending message integration, and stakeholder outreach for smooth implementation.
    April 9, 2026   Circulars Customs
    SCMTR transitional period extended; stakeholders must file correct electronic declarations while outreach programmes support compliance.
    April 9, 2026   Case Laws GST
    GST detention proceedings require timely seizure action, ownership determination from documents, and allowance of advocate representation.
    April 9, 2026   Case Laws GST
    Personal hearing is mandatory before confiscation under Section 130; order quashed for breach of natural justice.
    April 9, 2026   Case Laws GST
    Conditional restoration of GST registration granted where cancellation was only for non-filing of returns, without tax evasion allegations.
    April 9, 2026   Case Laws GST
    Premature writ challenge to ITC blockage notices deferred until replies are heard and factual issues are adjudicated
    April 9, 2026   Case Laws GST
    Parallel tax enforcement barred where duplicate proceedings led to quashing of bank account attachment and restoration of business access.
    April 9, 2026   Case Laws GST
    Transitional credit correction in revised TRAN-1 and TRAN-2 allowed; writ maintainable, assessment quashed, matter remitted.
    April 9, 2026   Case Laws GST
    Detention and confiscation in transit require section 129 to run its course before section 130 confiscation can be invoked.
    April 9, 2026   Case Laws GST
    Writ maintainability and GST rectification appeals: parallel writ relief barred, statutory appeal under Section 107 available
    April 9, 2026   Case Laws Income Tax
    Revisional power in block assessment upheld, undisclosed search income sustained, freight suppression addition restored, accrued lorry hire liability confirmed.
    April 9, 2026   Case Laws Income Tax
    Income recognition, energy tax, accrued liability and computer depreciation issues were all resolved against the Department.
    April 9, 2026   Case Laws Income Tax
    Procedural lapse cannot defeat concessional tax benefit where eligibility is undisputed and delay is short and bona fide.
    April 9, 2026   Case Laws Income Tax
    Section 170A limits post-amalgamation assessment to modification only where the assessment was already completed.
    April 9, 2026   Case Laws Income Tax
    Book profit treatment for bad debts and directory audit-report filing shaped the outcome on deduction claims.
    April 9, 2026   Case Laws Income Tax
    Bona fide treaty relief claim defeats penalty where income was disclosed and no concealment or inaccurate particulars were proved.
    April 9, 2026   Case Laws Income Tax
    Prior-period expenditure may be considered in the correct assessment year when genuineness is undisputed and revised computation is filed.
    April 9, 2026   Case Laws Income Tax
    Commercial expediency and rectification limits upheld as interest deduction was allowed and no apparent mistake was found.
    April 9, 2026   Case Laws Income Tax
    Reassessment and fee-for-technical-services classification: reopening upheld, but certain reimbursements and mobilization charges fell outside treaty taxation.

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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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