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    March 13, 2026   Case LawsGST
    Retrospective cancellation requires prior show cause notice with supplied material and reasoned order; otherwise cancellation is set aside.
    March 13, 2026   Case LawsGST
    Retrospective cancellation requires specific notice and disclosed material; absence of these invalidates the cancellation.
    March 13, 2026   Case LawsGST
    Deemed cancellation of GST registration on amalgamation: orders against non existent entity invalid; upload to successor registration.
    March 13, 2026   Case LawsIncome Tax
    Prima facie satisfaction to reopen under Section 148A does not require witness cross examination; cross examination may follow at Section 147 stage.
    March 13, 2026   Case LawsIncome Tax
    Charitable activity test: retained donations fell below monetary threshold so exemption upheld and appeal allowed.
    March 13, 2026   Case LawsIncome Tax
    Deduction for additional employee cost under 80JJAA upheld for three years; related disallowances deleted and FTC remitted.
    March 13, 2026   Case LawsIncome Tax
    Mandatory notice under section 143(2) is jurisdictional; absence vitiates assessment even if AO acted on the filed return.
    March 13, 2026   Case LawsIncome Tax
    Deductibility for charitable donations affirmed where payments to approved relief funds, even if CSR-driven, qualify under the donation deduction sche...
    March 13, 2026   Case LawsIncome Tax
    Demutualisation shares: holding period and cost trace to original membership, producing long-term capital gain treatment.
    March 13, 2026   Case LawsIncome Tax
    Accrual of Business Income: recognition occurs on possession and receipt of consideration, not on later registration.
    March 13, 2026   Case LawsIncome Tax
    Recognition of donee status must exist at donation; absence defeats weighted deduction, and late audit reports forfeit 80 IA claims.
    March 13, 2026   Case LawsIncome Tax
    Reassessment Notice Validity: notice issued in name of dissolved entity is invalid, prompting quashing of reassessment.
    March 13, 2026   Case LawsIncome Tax
    Interest on delayed VAT compensatory, therefore treated as deductible business expenditure under section 37(1) per precedent.
    March 13, 2026   Case LawsIncome Tax
    Right to confrontation and corroboration of third party digital evidence: lack of cross examination invalidates additions.
    March 13, 2026   Case LawsIncome Tax
    Disallowance of construction cost reversed where contractor confirmation and supporting documents negated an ad hoc 50% reduction.
    March 13, 2026   Case LawsIncome Tax
    Reopening of assessment based on investigation material upheld, and payments to entry providers taxed as unexplained expenditure.
    March 13, 2026   Case LawsIncome Tax
    Taxability of excess stock: undifferentiated pre year end stock offered as business income, not unexplained investment.
    March 13, 2026   Case LawsIncome Tax
    Exemption under Section 54F allows appellate authorities to admit belated claims and remit verification to assessing officer.
    March 13, 2026   Case LawsCustoms
    Mis-declaration in import descriptions must be deliberate to justify confiscation; withheld contemporaneous import documents invalidate value redeterm...
    March 13, 2026   Case LawsCustoms
    Liability for EPCG export shortfall: duty and interest sustained, but confiscation and penalties quashed where no fraud and causes beyond importer con...
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    March 13, 2026   Case Laws GST
    Retrospective cancellation requires prior show cause notice with supplied material and reasoned order; otherwise cancellation is set aside.
    March 13, 2026   Case Laws GST
    Retrospective cancellation requires specific notice and disclosed material; absence of these invalidates the cancellation.
    March 13, 2026   Case Laws GST
    Deemed cancellation of GST registration on amalgamation: orders against non existent entity invalid; upload to successor registration.
    March 13, 2026   Case Laws Income Tax
    Prima facie satisfaction to reopen under Section 148A does not require witness cross examination; cross examination may follow at Section 147 stage.
    March 13, 2026   Case Laws Income Tax
    Charitable activity test: retained donations fell below monetary threshold so exemption upheld and appeal allowed.
    March 13, 2026   Case Laws Income Tax
    Deduction for additional employee cost under 80JJAA upheld for three years; related disallowances deleted and FTC remitted.
    March 13, 2026   Case Laws Income Tax
    Mandatory notice under section 143(2) is jurisdictional; absence vitiates assessment even if AO acted on the filed return.
    March 13, 2026   Case Laws Income Tax
    Deductibility for charitable donations affirmed where payments to approved relief funds, even if CSR-driven, qualify under the donation deduction scheme.
    March 13, 2026   Case Laws Income Tax
    Demutualisation shares: holding period and cost trace to original membership, producing long-term capital gain treatment.
    March 13, 2026   Case Laws Income Tax
    Accrual of Business Income: recognition occurs on possession and receipt of consideration, not on later registration.
    March 13, 2026   Case Laws Income Tax
    Recognition of donee status must exist at donation; absence defeats weighted deduction, and late audit reports forfeit 80 IA claims.
    March 13, 2026   Case Laws Income Tax
    Reassessment Notice Validity: notice issued in name of dissolved entity is invalid, prompting quashing of reassessment.
    March 13, 2026   Case Laws Income Tax
    Interest on delayed VAT compensatory, therefore treated as deductible business expenditure under section 37(1) per precedent.
    March 13, 2026   Case Laws Income Tax
    Right to confrontation and corroboration of third party digital evidence: lack of cross examination invalidates additions.
    March 13, 2026   Case Laws Income Tax
    Disallowance of construction cost reversed where contractor confirmation and supporting documents negated an ad hoc 50% reduction.
    March 13, 2026   Case Laws Income Tax
    Reopening of assessment based on investigation material upheld, and payments to entry providers taxed as unexplained expenditure.
    March 13, 2026   Case Laws Income Tax
    Taxability of excess stock: undifferentiated pre year end stock offered as business income, not unexplained investment.
    March 13, 2026   Case Laws Income Tax
    Exemption under Section 54F allows appellate authorities to admit belated claims and remit verification to assessing officer.
    March 13, 2026   Case Laws Customs
    Mis-declaration in import descriptions must be deliberate to justify confiscation; withheld contemporaneous import documents invalidate value redetermination.
    March 13, 2026   Case Laws Customs
    Liability for EPCG export shortfall: duty and interest sustained, but confiscation and penalties quashed where no fraud and causes beyond importer control.

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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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