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    March 9, 2026   Case Laws Income Tax
    Certificate under Section 197 operates for entire assessment year, preventing deductor being treated as assessee in default.
    March 9, 2026   Case Laws Income Tax
    Jurisdictional limitation: AO cannot use seized material obtained after set-aside to complete the regular assessment.
    March 9, 2026   Case Laws Income Tax
    Disallowance for exempt income adjustments reversed, with TDS, software, ESOP and TNMM comparability rulings affirmed accordingly.
    March 9, 2026   Case Laws Income Tax
    Goodwill Amortisation as Extraordinary Item: adjust PLI under TNMM on remand; penalty initiation found premature.
    March 9, 2026   Case Laws Income Tax
    Infrastructure facility: energy-efficient public lighting held integral to road projects, qualifying the operator as a developer and eligible for dedu...
    March 9, 2026   Case Laws Income Tax
    Sanction for Reassessment invalid when granted by an incompetent authority; resulting notices and reassessment quashed.
    March 9, 2026   Case Laws Income Tax
    Vague Show Cause Notice invalidated; penalty deleted because absence of specified notices denied a proper opportunity to be heard.
    March 9, 2026   Case Laws Income Tax
    Deemed date of search treated as notice date, making assessment for an earlier year time barred and quashed.
    March 9, 2026   Case Laws Income Tax
    Fourth Proviso to Section 153A: extended-period inquiry requires a reasonable, material-based satisfaction that escaped income likely exceeds the thre...
    March 9, 2026   Case Laws Income Tax
    Limitation under Section 144C read with Section 153: final assessment quashed as time barred; revival possible after Supreme Court ruling.
    March 9, 2026   Case Laws Income Tax
    Deductibility of provision for standard assets upheld, revisional proceedings quashed and assessment restored in favour of the assessee.
    March 9, 2026   Case Laws Income Tax
    Limitation under section 144C: final assessment orders found time barred and quashed when read with section 153.
    March 9, 2026   Case Laws Income Tax
    Revisional power under section 263 cannot be invoked where the Assessing Officer made enquiries and adopted a plausible view.
    March 9, 2026   Case Laws Income Tax
    Income from House Property: licence fees treated as rent and must not be subjected to a fresh addition; AO to verify computation.
    March 9, 2026   Case Laws Income Tax
    Crystallisation of liability: business expenses deductible in the year liability arises even if paid later, given business purpose.
    March 9, 2026   Case Laws IBC
    Estoppel by acceptance of payment bars belated challenges to approved resolution plans; statutory employee dues treatment upheld.
    March 9, 2026   Case Laws IBC
    Financial debt from commercial-effect funding: repayment plus profit share treated as borrowing, enabling CIRP admission when default exists.
    March 9, 2026   Case Laws Money Laundering
    Provisional Attachment of proceeds upheld: earnings from promoting illicit deposit schemes treated as proceeds and recipient assets attachable.
    March 9, 2026   Case Laws Money Laundering
    Prima facie money laundering found; provisional attachment upheld but limited to quantifiable illicit proceeds, not full contract value.
    March 9, 2026   Case Laws Indian Laws
    Finality of higher-court orders prevents lower-court actions that prejudice beneficiaries; non-parties retain remedies to challenge effects.
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March 9, 2026   Case Laws Income Tax
Certificate under Section 197 operates for entire assessment year, preventing deductor being treated as assessee in default.
March 9, 2026   Case Laws Income Tax
Jurisdictional limitation: AO cannot use seized material obtained after set-aside to complete the regular assessment.
March 9, 2026   Case Laws Income Tax
Disallowance for exempt income adjustments reversed, with TDS, software, ESOP and TNMM comparability rulings affirmed accordingly.
March 9, 2026   Case Laws Income Tax
Goodwill Amortisation as Extraordinary Item: adjust PLI under TNMM on remand; penalty initiation found premature.
March 9, 2026   Case Laws Income Tax
Infrastructure facility: energy-efficient public lighting held integral to road projects, qualifying the operator as a developer and eligible for deduction.
March 9, 2026   Case Laws Income Tax
Sanction for Reassessment invalid when granted by an incompetent authority; resulting notices and reassessment quashed.
March 9, 2026   Case Laws Income Tax
Vague Show Cause Notice invalidated; penalty deleted because absence of specified notices denied a proper opportunity to be heard.
March 9, 2026   Case Laws Income Tax
Deemed date of search treated as notice date, making assessment for an earlier year time barred and quashed.
March 9, 2026   Case Laws Income Tax
Fourth Proviso to Section 153A: extended-period inquiry requires a reasonable, material-based satisfaction that escaped income likely exceeds the threshold.
March 9, 2026   Case Laws Income Tax
Limitation under Section 144C read with Section 153: final assessment quashed as time barred; revival possible after Supreme Court ruling.
March 9, 2026   Case Laws Income Tax
Deductibility of provision for standard assets upheld, revisional proceedings quashed and assessment restored in favour of the assessee.
March 9, 2026   Case Laws Income Tax
Limitation under section 144C: final assessment orders found time barred and quashed when read with section 153.
March 9, 2026   Case Laws Income Tax
Revisional power under section 263 cannot be invoked where the Assessing Officer made enquiries and adopted a plausible view.
March 9, 2026   Case Laws Income Tax
Income from House Property: licence fees treated as rent and must not be subjected to a fresh addition; AO to verify computation.
March 9, 2026   Case Laws Income Tax
Crystallisation of liability: business expenses deductible in the year liability arises even if paid later, given business purpose.
March 9, 2026   Case Laws IBC
Estoppel by acceptance of payment bars belated challenges to approved resolution plans; statutory employee dues treatment upheld.
March 9, 2026   Case Laws IBC
Financial debt from commercial-effect funding: repayment plus profit share treated as borrowing, enabling CIRP admission when default exists.
March 9, 2026   Case Laws Money Laundering
Provisional Attachment of proceeds upheld: earnings from promoting illicit deposit schemes treated as proceeds and recipient assets attachable.
March 9, 2026   Case Laws Money Laundering
Prima facie money laundering found; provisional attachment upheld but limited to quantifiable illicit proceeds, not full contract value.
March 9, 2026   Case Laws Indian Laws
Finality of higher-court orders prevents lower-court actions that prejudice beneficiaries; non-parties retain remedies to challenge effects.

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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 Tax March 27, 2026 Case Laws AT
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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Acts Income Tax
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