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    March 5, 2026   Case Laws GST
    Pure service exemption for municipal waste transport confirmed; activity qualifies as a municipal function and is tax exempt.
    March 5, 2026   Case Laws GST
    Principal supply rule: hookah served in restaurants is treated as supply of goods, not restaurant service, and taxed by classification.
    March 5, 2026   Case Laws Income Tax
    Non-communication of a court order nullified a subsequent assessment; fresh reply and re order mandated with extended timelines.
    March 5, 2026   Case Laws Income Tax
    Tax withholding certificate challenged for failure to apply precedent; authority ordered to issue a reduced treaty-based deduction certificate.
    March 5, 2026   Case Laws Income Tax
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    March 5, 2026   Case Laws Income Tax
    Retrospective application of amended Section 12AB(4) barred; cancellations cannot target years before its commencement, thus registration restored.
    March 5, 2026   Case Laws Income Tax
    Religious purpose exclusion versus charitable purpose: non overriding religious objects do not attract Explanation 3, registration directed under sect...
    March 5, 2026   Case Laws Income Tax
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    March 5, 2026   Case Laws Income Tax
    Computation of insurance business profits: regulatory reallocation of management expenses remains deductible; related penalty cancelled.
    March 5, 2026   Case Laws Income Tax
    Grandfathering proviso to Section 149(1)(b) bars reopening beyond old-regime block; approvals require independent application of mind.
    March 5, 2026   Case Laws Income Tax
    Search-assessment proviso jurisdiction, time-barred valuation reports, and denial of cross-examination vitiate valuation-based and confession-based ad...
    March 5, 2026   Case Laws Income Tax
    Reopening under Section 147 cannot be invoked where third party seized material triggers Section 153C; reassessment quashed.
    March 5, 2026   Case Laws Income Tax
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    March 5, 2026   Case Laws Customs
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    March 5, 2026   Case Laws Customs
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    March 5, 2026   Case Laws Companies Law
    Distinction between commercial decisions and criminality: court quashed FIR where no prima facie fraud or identified accused.
    March 5, 2026   Case Laws IBC
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    March 5, 2026   Case Laws FEMA
    Company Striking Off: liabilities and penalties survive; legal representatives liable limited to estate; Section 13(1) FEMA needs no mens rea.
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March 5, 2026   Case Laws GST
Pure service exemption for municipal waste transport confirmed; activity qualifies as a municipal function and is tax exempt.
March 5, 2026   Case Laws GST
Principal supply rule: hookah served in restaurants is treated as supply of goods, not restaurant service, and taxed by classification.
March 5, 2026   Case Laws Income Tax
Non-communication of a court order nullified a subsequent assessment; fresh reply and re order mandated with extended timelines.
March 5, 2026   Case Laws Income Tax
Tax withholding certificate challenged for failure to apply precedent; authority ordered to issue a reduced treaty-based deduction certificate.
March 5, 2026   Case Laws Income Tax
Denial of Hearing in Faceless Assessment invalidates proceedings; reopen, allow filing of reply and provide hearing before fresh adjudication.
March 5, 2026   Case Laws Income Tax
Royalty taxation: notional royalty disallowed without contractual right; no PE attribution, royalties taxed at treaty rate.
March 5, 2026   Case Laws Income Tax
Mandatory signature requirement for electronic tax notices invalidates unsigned reopening notices and denies jurisdiction for reassessment.
March 5, 2026   Case Laws Income Tax
Retrospective application of amended Section 12AB(4) barred; cancellations cannot target years before its commencement, thus registration restored.
March 5, 2026   Case Laws Income Tax
Religious purpose exclusion versus charitable purpose: non overriding religious objects do not attract Explanation 3, registration directed under section 80G.
March 5, 2026   Case Laws Income Tax
Cancellation of charitable registration overturned where unverified adverse inferences, not proper enquiry, drove the revocation.
March 5, 2026   Case Laws Income Tax
Computation of insurance business profits: regulatory reallocation of management expenses remains deductible; related penalty cancelled.
March 5, 2026   Case Laws Income Tax
Grandfathering proviso to Section 149(1)(b) bars reopening beyond old-regime block; approvals require independent application of mind.
March 5, 2026   Case Laws Income Tax
Search-assessment proviso jurisdiction, time-barred valuation reports, and denial of cross-examination vitiate valuation-based and confession-based additions.
March 5, 2026   Case Laws Income Tax
Reopening under Section 147 cannot be invoked where third party seized material triggers Section 153C; reassessment quashed.
March 5, 2026   Case Laws Income Tax
Conduit bank account used for third party funds: credited sums treated as routed transactions and only commission assessed as income.
March 5, 2026   Case Laws Customs
Customs Valuation Principle: classification as furniture upheld but administrative valuation benchmarks cannot displace statutory valuation rules.
March 5, 2026   Case Laws Customs
Conditional exemption for imported aircraft covers use in non-scheduled charter services, so duty and penalties set aside.
March 5, 2026   Case Laws Companies Law
Distinction between commercial decisions and criminality: court quashed FIR where no prima facie fraud or identified accused.
March 5, 2026   Case Laws IBC
Condonation of Delay under the IBC: statutory limits on appeal timelines cannot be enlarged by Section 198, appeal dismissed.
March 5, 2026   Case Laws FEMA
Company Striking Off: liabilities and penalties survive; legal representatives liable limited to estate; Section 13(1) FEMA needs no mens rea.

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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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