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    March 18, 2026   Case LawsCustoms
    Limitation on Customs show cause notices: extended period unavailable where department had prior knowledge, so SCN held time barred.
    March 18, 2026   Case LawsCustoms
    Anticipatory Bail granted on conditions balancing presumption of innocence with investigative needs; passport surrender and regular attendance require...
    March 18, 2026   Case LawsIBC
    Insolvency eligibility: see-through analysis of de facto control found applicant disqualified, CIRP to continue pending inquiry.
    March 18, 2026   Case LawsIBC
    Presumption of Service: deemed Form B notice and concealment of developments led to dismissal and costs imposed.
    March 18, 2026   Case LawsFEMA
    Mitigation for delayed adjudication reduces penalty though contravention established by documentary and corroborative evidence.
    March 18, 2026   Case LawsFEMA
    Civil penalty liability under FEMA: mens rea not required; penalty reduced and pre-deposit to be adjusted accordingly.
    March 18, 2026   Case LawsFEMA
    Foreign exchange derivative prohibition confirmed; civil penalties apply without mens rea and mitigation reduced the quantified penalty.
    March 18, 2026   Case LawsMoney Laundering
    Electronic Service Validity: email service upheld, RUDs remitted for supply by Adjudicating Authority and supplementary reply allowed.
    March 18, 2026   Case LawsMoney Laundering
    Freezing power under PMLA may be applied where investigative material gives reasons to believe proceeds of crime, even despite prior encumbrances.
    March 18, 2026   Case LawsMoney Laundering
    Provisional attachment under PMLA confirmed where seized records and corroboration showed forged degrees and undisclosed proceeds of crime.
    March 18, 2026   Case LawsMoney Laundering
    Proceeds of crime: excess excavation quantified as wrongful gain; equivalent-value property may be provisionally attached when taint is untraceable.
    March 18, 2026   Case LawsIndian Laws
    Breach of natural justice: reliance on fresh charges and lack of reasons invalidates removal, writ entertained and order set aside.
    March 17, 2026   NotificationsDGFT
    Import Policy change: specified jewellery ITC codes shifted from Free to Restricted with immediate effect.
    March 17, 2026   NotificationsSEBI
    Minimum Public Offer Requirements set tiered issuer-based allotment minima with mandatory staged public shareholding increases and exchange enforcemen...
    March 17, 2026   CircularsCustoms
    Container Movement Procedure: auto approved movement numbers permit terminal transfer to CFSs with escalation and manual approval safeguards.
    March 17, 2026   CircularsCustoms
    Export Cargo Return Procedures: permit berth, require seal verification, cancel Shipping Bills/LEO after incentive recovery.
    March 17, 2026   CircularsCustoms
    Parawise Comments requirement: concerned sections must prepare and forward comments to enable timely filing of counter-affidavits.
    March 17, 2026   Case LawsGST
    Validity of time extension notifications - statutory appeal allowed within four weeks; appellate outcome subject to pending substantive challenge.
    March 17, 2026   Case LawsGST
    Concessional IGST entitlement denied where prescribed supplier recipient order and movement conditions are not strictly complied with.
    March 17, 2026   Case LawsGST
    Time limit for Input Tax Credit extended retrospectively; claims within the extended period permitted and remitted for factual eligibility review.
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    March 18, 2026   Case Laws Customs
    Limitation on Customs show cause notices: extended period unavailable where department had prior knowledge, so SCN held time barred.
    March 18, 2026   Case Laws Customs
    Anticipatory Bail granted on conditions balancing presumption of innocence with investigative needs; passport surrender and regular attendance required.
    March 18, 2026   Case Laws IBC
    Insolvency eligibility: see-through analysis of de facto control found applicant disqualified, CIRP to continue pending inquiry.
    March 18, 2026   Case Laws IBC
    Presumption of Service: deemed Form B notice and concealment of developments led to dismissal and costs imposed.
    March 18, 2026   Case Laws FEMA
    Mitigation for delayed adjudication reduces penalty though contravention established by documentary and corroborative evidence.
    March 18, 2026   Case Laws FEMA
    Civil penalty liability under FEMA: mens rea not required; penalty reduced and pre-deposit to be adjusted accordingly.
    March 18, 2026   Case Laws FEMA
    Foreign exchange derivative prohibition confirmed; civil penalties apply without mens rea and mitigation reduced the quantified penalty.
    March 18, 2026   Case Laws Money Laundering
    Electronic Service Validity: email service upheld, RUDs remitted for supply by Adjudicating Authority and supplementary reply allowed.
    March 18, 2026   Case Laws Money Laundering
    Freezing power under PMLA may be applied where investigative material gives reasons to believe proceeds of crime, even despite prior encumbrances.
    March 18, 2026   Case Laws Money Laundering
    Provisional attachment under PMLA confirmed where seized records and corroboration showed forged degrees and undisclosed proceeds of crime.
    March 18, 2026   Case Laws Money Laundering
    Proceeds of crime: excess excavation quantified as wrongful gain; equivalent-value property may be provisionally attached when taint is untraceable.
    March 18, 2026   Case Laws Indian Laws
    Breach of natural justice: reliance on fresh charges and lack of reasons invalidates removal, writ entertained and order set aside.
    March 17, 2026   Notifications DGFT
    Import Policy change: specified jewellery ITC codes shifted from Free to Restricted with immediate effect.
    March 17, 2026   Notifications SEBI
    Minimum Public Offer Requirements set tiered issuer-based allotment minima with mandatory staged public shareholding increases and exchange enforcement.
    March 17, 2026   Circulars Customs
    Container Movement Procedure: auto approved movement numbers permit terminal transfer to CFSs with escalation and manual approval safeguards.
    March 17, 2026   Circulars Customs
    Export Cargo Return Procedures: permit berth, require seal verification, cancel Shipping Bills/LEO after incentive recovery.
    March 17, 2026   Circulars Customs
    Parawise Comments requirement: concerned sections must prepare and forward comments to enable timely filing of counter-affidavits.
    March 17, 2026   Case Laws GST
    Validity of time extension notifications - statutory appeal allowed within four weeks; appellate outcome subject to pending substantive challenge.
    March 17, 2026   Case Laws GST
    Concessional IGST entitlement denied where prescribed supplier recipient order and movement conditions are not strictly complied with.
    March 17, 2026   Case Laws GST
    Time limit for Input Tax Credit extended retrospectively; claims within the extended period permitted and remitted for factual eligibility review.

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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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