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    March 20, 2026   Case LawsIncome Tax
    Extended limitation for reassessment not triggered by procedural remand; ordinary limitation applied and reassessment held time barred.
    March 20, 2026   Case LawsIncome Tax
    Irrevocability of public charitable trusts arises by law; lack of an express clause cannot justify registration rejection.
    March 20, 2026   Case LawsIncome Tax
    Service by Email: recorded email addresses validate notices but pandemic excuse may condone appeal delay, subject to deposit.
    March 20, 2026   Case LawsIncome Tax
    Slump Sale qualifies where consideration is lump sum without asset wise valuation; capital gains computed under special net worth rule.
    March 20, 2026   Case LawsIncome Tax
    Depreciation on Goodwill denied where not capitalised; SEZ unit loss set off remitted for AO verification and recomputation.
    March 20, 2026   Case LawsIncome Tax
    Reopening of assessment invalid where approval rests on erroneous facts; onus under section 68 shifts to AO to rebut documentary proof.
    March 20, 2026   Case LawsIncome Tax
    Allowability of business expenditure: captive power costs upheld as deductible; Rule 8D disallowance limited to exempt income.
    March 20, 2026   Case LawsIncome Tax
    Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
    March 20, 2026   Case LawsIncome Tax
    Indexed cost of improvement: 80% of claimed improvement allowed despite incomplete proof, AO directed to recompute deduction.
    March 20, 2026   Case LawsIncome Tax
    Audi Alteram Partem breach invalidates disallowance where authorities ignore available documentary evidence; addition set aside.
    March 20, 2026   Case LawsIncome Tax
    Electronic chat evidence: WhatsApp messages alone cannot prove unexplained investment; corroborative seized material and statements required.
    March 20, 2026   Case LawsIncome Tax
    Jurisdiction under Section 153C invalid for lack of incriminating material; additions deleted and earlier years quashed.
    March 20, 2026   Case LawsIncome Tax
    Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
    March 20, 2026   Case LawsIncome Tax
    Mandatory Signature Requirement: unsigned income tax notices are invalid and cannot sustain reassessment proceedings under law.
    March 20, 2026   Case LawsCustoms
    Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
    March 20, 2026   Case LawsCustoms
    Improper import standard: invalid inspection certificates alone do not justify confiscation; penalties require proof of abetment mens rea.
    March 20, 2026   Case LawsCustoms
    Presumption of smuggling: possession, recovery and an un retracted admission sustain confiscation when lawful origin is not proved.
    March 20, 2026   Case LawsCustoms
    Customs Broker Liability: penalty requires specific proof of the broker's facilitation of export overvaluation, or it must be set aside.
    March 20, 2026   Case LawsCustoms
    Classification of printed technical documents: specific Chapter 49.01 entry prevails, enabling claimed customs exemptions for imported manuals and rep...
    March 20, 2026   Case LawsCustoms
    Specific tariff classification: APIs and bulk drugs are treated as drugs and attract IGST under the specific entry.
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    March 20, 2026   Case Laws Income Tax
    Extended limitation for reassessment not triggered by procedural remand; ordinary limitation applied and reassessment held time barred.
    March 20, 2026   Case Laws Income Tax
    Irrevocability of public charitable trusts arises by law; lack of an express clause cannot justify registration rejection.
    March 20, 2026   Case Laws Income Tax
    Service by Email: recorded email addresses validate notices but pandemic excuse may condone appeal delay, subject to deposit.
    March 20, 2026   Case Laws Income Tax
    Slump Sale qualifies where consideration is lump sum without asset wise valuation; capital gains computed under special net worth rule.
    March 20, 2026   Case Laws Income Tax
    Depreciation on Goodwill denied where not capitalised; SEZ unit loss set off remitted for AO verification and recomputation.
    March 20, 2026   Case Laws Income Tax
    Reopening of assessment invalid where approval rests on erroneous facts; onus under section 68 shifts to AO to rebut documentary proof.
    March 20, 2026   Case Laws Income Tax
    Allowability of business expenditure: captive power costs upheld as deductible; Rule 8D disallowance limited to exempt income.
    March 20, 2026   Case Laws Income Tax
    Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted documentary proof.
    March 20, 2026   Case Laws Income Tax
    Indexed cost of improvement: 80% of claimed improvement allowed despite incomplete proof, AO directed to recompute deduction.
    March 20, 2026   Case Laws Income Tax
    Audi Alteram Partem breach invalidates disallowance where authorities ignore available documentary evidence; addition set aside.
    March 20, 2026   Case Laws Income Tax
    Electronic chat evidence: WhatsApp messages alone cannot prove unexplained investment; corroborative seized material and statements required.
    March 20, 2026   Case Laws Income Tax
    Jurisdiction under Section 153C invalid for lack of incriminating material; additions deleted and earlier years quashed.
    March 20, 2026   Case Laws Income Tax
    Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mine-closure deductions sustained.
    March 20, 2026   Case Laws Income Tax
    Mandatory Signature Requirement: unsigned income tax notices are invalid and cannot sustain reassessment proceedings under law.
    March 20, 2026   Case Laws Customs
    Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties and orders
    March 20, 2026   Case Laws Customs
    Improper import standard: invalid inspection certificates alone do not justify confiscation; penalties require proof of abetment mens rea.
    March 20, 2026   Case Laws Customs
    Presumption of smuggling: possession, recovery and an un retracted admission sustain confiscation when lawful origin is not proved.
    March 20, 2026   Case Laws Customs
    Customs Broker Liability: penalty requires specific proof of the broker's facilitation of export overvaluation, or it must be set aside.
    March 20, 2026   Case Laws Customs
    Classification of printed technical documents: specific Chapter 49.01 entry prevails, enabling claimed customs exemptions for imported manuals and reports.
    March 20, 2026   Case Laws Customs
    Specific tariff classification: APIs and bulk drugs are treated as drugs and attract IGST under the specific entry.

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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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