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    March 6, 2026   Case Laws Customs
    Voluntariness of statement: statements in an unknown language and retracted admissions undermine valuation adjustments and penalties.
    March 6, 2026   Case Laws IBC
    Necessary Party Test: impleadment refused as resolution professional can represent corporate debtor and appeal proceeds without applicant.
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    Pre-existing dispute plausibility barred the insolvency petition and the demand notice was prima facie premature under contract terms.
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    March 6, 2026   Case Laws FEMA
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    Renting of immovable property exclusion: leased hotel premises remain excluded as buildings used for accommodation; Explanation 2 not attracted.
    March 6, 2026   Case Laws Service Tax
    Cum-tax valuation: invoices showing tax separately prevent cum-tax benefit; tax and interest payable, penalty relief granted.
    March 5, 2026   Circulars SEBI
    Categorization of Mutual Fund Schemes: uniform scheme categories, allocation rules and overlap limits imposed with compliance timelines.
    March 5, 2026   Circulars Customs
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    March 5, 2026   Circulars Customs
    Deferred Payment of Customs Duty extended to Eligible Manufacturer Importers with electronic registration and ICEGATE authentication for conditional c...
    March 5, 2026   Case Laws GST
    Tariff classification determines GST schedule and rate; beverages in Schedule III attract the higher rate, tea extracts and syrups in Schedule I attra...
    March 5, 2026   Case Laws GST
    Pure Services classification applies to security guards, but recipient-based exemption excludes service supplied to a Government Entity.
    March 5, 2026   Case Laws IBC
    Fraudulent trading requires cogent evidence of intent to defraud; ordinary-course payments protected, except post-insolvency withdrawals must be resto...
    March 5, 2026   Case Laws IBC
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    March 5, 2026   Case Laws GST
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    March 5, 2026   Case Laws GST
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    March 5, 2026   Case Laws GST
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    March 5, 2026   Case Laws GST
    Audi alteram partem requires fresh consideration with a hearing; authorities must re-examine the representation and decide expeditiously.
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March 6, 2026   Case Laws Customs
Voluntariness of statement: statements in an unknown language and retracted admissions undermine valuation adjustments and penalties.
March 6, 2026   Case Laws IBC
Necessary Party Test: impleadment refused as resolution professional can represent corporate debtor and appeal proceeds without applicant.
March 6, 2026   Case Laws IBC
Pre-existing dispute plausibility barred the insolvency petition and the demand notice was prima facie premature under contract terms.
March 6, 2026   Case Laws IBC
Lease Deed validity denied where unauthorized execution and no proof of consideration; disputed asset excluded from insolvency estate.
March 6, 2026   Case Laws Money Laundering
Proceeds of crime includes property value or equivalent, allowing attachment even if the holder is not accused.
March 6, 2026   Case Laws FEMA
Round tripping found where overseas WOS used to obtain foreign borrowings and reinvest in domestic group, penalties sustained.
March 6, 2026   Case Laws Service Tax
Renting of immovable property exclusion: leased hotel premises remain excluded as buildings used for accommodation; Explanation 2 not attracted.
March 6, 2026   Case Laws Service Tax
Cum-tax valuation: invoices showing tax separately prevent cum-tax benefit; tax and interest payable, penalty relief granted.
March 5, 2026   Circulars SEBI
Categorization of Mutual Fund Schemes: uniform scheme categories, allocation rules and overlap limits imposed with compliance timelines.
March 5, 2026   Circulars Customs
Sample Testing Timelines mandated for revenue laboratories to report category-based tests from date of receipt, subject to capacity constraints.
March 5, 2026   Circulars Customs
Hazardous cargo declaration at item level required; system flags such goods and officers must record details if CTH changes.
March 5, 2026   Circulars Customs
Deferred Payment of Customs Duty extended to Eligible Manufacturer Importers with electronic registration and ICEGATE authentication for conditional clearance.
March 5, 2026   Case Laws GST
Tariff classification determines GST schedule and rate; beverages in Schedule III attract the higher rate, tea extracts and syrups in Schedule I attract the lower rate.
March 5, 2026   Case Laws GST
Pure Services classification applies to security guards, but recipient-based exemption excludes service supplied to a Government Entity.
March 5, 2026   Case Laws IBC
Fraudulent trading requires cogent evidence of intent to defraud; ordinary-course payments protected, except post-insolvency withdrawals must be restored.
March 5, 2026   Case Laws IBC
Imposition of costs on financial creditors struck down for lack of recorded reasons following withdrawal under insolvency procedure.
March 5, 2026   Case Laws GST
Transfer of immovable property benefits is not a taxable supply of services; classification as miscellaneous service quashed.
March 5, 2026   Case Laws GST
Cancellation of GST registration set aside for lack of reasons and denial of hearing; remitted for fresh adjudication after permitting reply.
March 5, 2026   Case Laws GST
Writ jurisdiction revival of cancelled GST registration permitted subject to compliance with return filing, payment and ITC safeguards.
March 5, 2026   Case Laws GST
Audi alteram partem requires fresh consideration with a hearing; authorities must re-examine the representation and decide expeditiously.

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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 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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