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    March 19, 2026   Case LawsGST
    Taxability of vouchers: vouchers not taxable per se; only underlying supplies and agent commission may attract GST, remitted for fresh decision.
    March 19, 2026   Case LawsGST
    Prematurity of writs: challenge statutory search and seizure only after exhausting CGST adjudication; provisional release available by procedure.
    March 19, 2026   Case LawsGST
    Fair opportunity to be heard: adjudication may proceed on other materials if originals of seized documents are not relied upon.
    March 19, 2026   Case LawsGST
    Procedural fairness: order passed without reply quashed and remitted subject to conditional pre-deposit and filing of reply.
    March 19, 2026   Case LawsGST
    Duplication of proceedings quashed; remand ordered subject to conditional payment and fresh personal hearing.
    March 19, 2026   Case LawsGST
    Effective service of notices: portal-only notice insufficient; order set aside and fresh hearing ordered with bank attachment released.
    March 19, 2026   Case LawsGST
    Service by electronic portal: failure to secure effective service and personal hearing requires remand and fresh consideration.
    March 19, 2026   Case LawsGST
    Classification by primary use determines concessional rate if rubber rings are hard rubber and solely for irrigation.
    March 19, 2026   Case LawsIncome Tax
    Abstention in parallel proceedings: court dismissed fresh writ where identical issue was pending, liberty to seek additional question.
    March 19, 2026   Case LawsIncome Tax
    Abatement of assessment: completed assessments survive search but a subsequent Section 153A block assessment merges prior orders.
    March 19, 2026   Case LawsIncome Tax
    Power to receive documentary evidence upheld; documents referred in complaint may be placed on record without amendment where omission was inadvertent...
    March 19, 2026   Case LawsIncome Tax
    Right to disclosure: originals of foreign documents on the record; admissibility and authentication to be decided at trial.
    March 19, 2026   Case LawsIncome Tax
    Proof of foreign public documents requires originals or certified diplomatic/notarial copies; inspection must occur in-magna presence and cross-examin...
    March 19, 2026   Case LawsIncome Tax
    Assessment against a ceased amalgamating company lacks jurisdiction; notices issued in its name are void but Revenue may proceed afresh.
    March 19, 2026   Case LawsIncome Tax
    Revisional power: not available for mere difference of opinion; AO's findings on cash credits upheld on record.
    March 19, 2026   Case LawsIncome Tax
    Limitation on carry forward of capital losses upheld; interest on delayed compensation treated as deductible income.
    March 19, 2026   Case LawsIncome Tax
    Exemption for retrenchment compensation: government approved VRS severance held non taxable under section 10(10B).
    March 19, 2026   Case LawsIncome Tax
    Tax Collection at Source: documentary return reconciliation established collection and deposit, so additional TCS levy was set aside.
    March 19, 2026   Case LawsIncome Tax
    Determination of income without rejecting books: suo motu net profit addition deleted; parking slots remitted; capitalised interest allowed.
    March 19, 2026   Case LawsIncome Tax
    TDS non-deduction under section 40(a)(ia) limited to 30%; unexplained cash credits require primary evidence rebuttal.
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    March 19, 2026   Case Laws GST
    Taxability of vouchers: vouchers not taxable per se; only underlying supplies and agent commission may attract GST, remitted for fresh decision.
    March 19, 2026   Case Laws GST
    Prematurity of writs: challenge statutory search and seizure only after exhausting CGST adjudication; provisional release available by procedure.
    March 19, 2026   Case Laws GST
    Fair opportunity to be heard: adjudication may proceed on other materials if originals of seized documents are not relied upon.
    March 19, 2026   Case Laws GST
    Procedural fairness: order passed without reply quashed and remitted subject to conditional pre-deposit and filing of reply.
    March 19, 2026   Case Laws GST
    Duplication of proceedings quashed; remand ordered subject to conditional payment and fresh personal hearing.
    March 19, 2026   Case Laws GST
    Effective service of notices: portal-only notice insufficient; order set aside and fresh hearing ordered with bank attachment released.
    March 19, 2026   Case Laws GST
    Service by electronic portal: failure to secure effective service and personal hearing requires remand and fresh consideration.
    March 19, 2026   Case Laws GST
    Classification by primary use determines concessional rate if rubber rings are hard rubber and solely for irrigation.
    March 19, 2026   Case Laws Income Tax
    Abstention in parallel proceedings: court dismissed fresh writ where identical issue was pending, liberty to seek additional question.
    March 19, 2026   Case Laws Income Tax
    Abatement of assessment: completed assessments survive search but a subsequent Section 153A block assessment merges prior orders.
    March 19, 2026   Case Laws Income Tax
    Power to receive documentary evidence upheld; documents referred in complaint may be placed on record without amendment where omission was inadvertent.
    March 19, 2026   Case Laws Income Tax
    Right to disclosure: originals of foreign documents on the record; admissibility and authentication to be decided at trial.
    March 19, 2026   Case Laws Income Tax
    Proof of foreign public documents requires originals or certified diplomatic/notarial copies; inspection must occur in-magna presence and cross-examination proceed immediately.
    March 19, 2026   Case Laws Income Tax
    Assessment against a ceased amalgamating company lacks jurisdiction; notices issued in its name are void but Revenue may proceed afresh.
    March 19, 2026   Case Laws Income Tax
    Revisional power: not available for mere difference of opinion; AO's findings on cash credits upheld on record.
    March 19, 2026   Case Laws Income Tax
    Limitation on carry forward of capital losses upheld; interest on delayed compensation treated as deductible income.
    March 19, 2026   Case Laws Income Tax
    Exemption for retrenchment compensation: government approved VRS severance held non taxable under section 10(10B).
    March 19, 2026   Case Laws Income Tax
    Tax Collection at Source: documentary return reconciliation established collection and deposit, so additional TCS levy was set aside.
    March 19, 2026   Case Laws Income Tax
    Determination of income without rejecting books: suo motu net profit addition deleted; parking slots remitted; capitalised interest allowed.
    March 19, 2026   Case Laws Income Tax
    TDS non-deduction under section 40(a)(ia) limited to 30%; unexplained cash credits require primary evidence rebuttal.

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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 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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