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    February 26, 2026   Case Laws GST
    Reverse Charge Mechanism and ITC reversal require fresh adjudication to assess repeal impact and conditional relief.
    February 26, 2026   Case Laws GST
    Interest on Wrongful Input Tax Credit is mandatory where excess transitional credit was retained and later reversed, and related objections were rejec...
    February 26, 2026   Case Laws GST
    Blocking of electronic credit ledger requires written reasons, a show cause process and a hearing before a speaking order is issued.
    February 26, 2026   Case Laws GST
    Overlap of tax assessments requires remand for fresh adjudication; taxpayers must particularize and substantiate pre GST transactions.
    February 26, 2026   Case Laws GST
    Tariff classification: paddle wheel aerators treated as residual machines, not agricultural machinery, affecting GST treatment.
    February 26, 2026   Case Laws GST
    Advance Payment as Consideration: GST liability arises on receipt of advance unless an earlier invoice is issued.
    February 26, 2026   Case Laws GST
    Characterisation of supply by place of preparation: retail prepared food is restaurant service (no ITC); B2B ice cream is goods with ITC.
    February 26, 2026   Case Laws GST
    Mixed supply characterization for bundled printing consumables - treated as mixed, continuous supply; time and value follow invoice/per-click terms.
    February 26, 2026   Case Laws Income Tax
    Personal information of an assessee is ordinarily exempt under RTI unless larger public interest compels disclosure.
    February 26, 2026   Case Laws Income Tax
    Voluntary Admission of Income: a taxpayer's declared income in a filed return cannot be reduced by the Assessing Officer on scrutiny.
    February 26, 2026   Case Laws Income Tax
    Withholding Tax Certificate: authority ordered to reissue at a lower rate and permit return filing subject to CBDT scrutiny.
    February 26, 2026   Case Laws Income Tax
    Disallowance of interest to scheduled/cooperative banks upheld where unpaid by the return filing due date, favouring revenue.
    February 26, 2026   Case Laws Income Tax
    Omission of statutory provision prevents TPO reference for ALP; consequent adjustments invalid and revenue appeal dismissed.
    February 26, 2026   Case Laws Income Tax
    Updated Return Timing permits claiming charitable exemption when filed within the belated-return period; precedent supports allowance.
    February 26, 2026   Case Laws Income Tax
    Manufacture qualification under Section 80IC upheld for unit converting electrical steel into laminations, deduction allowed.
    February 26, 2026   Case Laws Income Tax
    Reassessment notice validity: extended notices without prescribed conditions or pre-reopening consultation are invalid and quashed.
    February 26, 2026   Case Laws Income Tax
    Reopening Assessments invalid where satisfaction and jurisdictional approval are absent for third party seized material, leading to quashing of assess...
    February 26, 2026   Case Laws Income Tax
    Limitation under Section 153: period lost during handover of books is excluded; assessment beyond extended deadline is time-barred.
    February 26, 2026   Case Laws Income Tax
    Section 269SS cash receipt rule: recorded sale consideration and absent AO satisfaction or limitation can negate penalty under Section 271D.
    February 26, 2026   Case Laws Income Tax
    Trust purchase prohibition: tribunal found exemption preserved where sellers lacked substantial interest or control in the investee.
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February 26, 2026   Case Laws GST
Reverse Charge Mechanism and ITC reversal require fresh adjudication to assess repeal impact and conditional relief.
February 26, 2026   Case Laws GST
Interest on Wrongful Input Tax Credit is mandatory where excess transitional credit was retained and later reversed, and related objections were rejected.
February 26, 2026   Case Laws GST
Blocking of electronic credit ledger requires written reasons, a show cause process and a hearing before a speaking order is issued.
February 26, 2026   Case Laws GST
Overlap of tax assessments requires remand for fresh adjudication; taxpayers must particularize and substantiate pre GST transactions.
February 26, 2026   Case Laws GST
Tariff classification: paddle wheel aerators treated as residual machines, not agricultural machinery, affecting GST treatment.
February 26, 2026   Case Laws GST
Advance Payment as Consideration: GST liability arises on receipt of advance unless an earlier invoice is issued.
February 26, 2026   Case Laws GST
Characterisation of supply by place of preparation: retail prepared food is restaurant service (no ITC); B2B ice cream is goods with ITC.
February 26, 2026   Case Laws GST
Mixed supply characterization for bundled printing consumables - treated as mixed, continuous supply; time and value follow invoice/per-click terms.
February 26, 2026   Case Laws Income Tax
Personal information of an assessee is ordinarily exempt under RTI unless larger public interest compels disclosure.
February 26, 2026   Case Laws Income Tax
Voluntary Admission of Income: a taxpayer's declared income in a filed return cannot be reduced by the Assessing Officer on scrutiny.
February 26, 2026   Case Laws Income Tax
Withholding Tax Certificate: authority ordered to reissue at a lower rate and permit return filing subject to CBDT scrutiny.
February 26, 2026   Case Laws Income Tax
Disallowance of interest to scheduled/cooperative banks upheld where unpaid by the return filing due date, favouring revenue.
February 26, 2026   Case Laws Income Tax
Omission of statutory provision prevents TPO reference for ALP; consequent adjustments invalid and revenue appeal dismissed.
February 26, 2026   Case Laws Income Tax
Updated Return Timing permits claiming charitable exemption when filed within the belated-return period; precedent supports allowance.
February 26, 2026   Case Laws Income Tax
Manufacture qualification under Section 80IC upheld for unit converting electrical steel into laminations, deduction allowed.
February 26, 2026   Case Laws Income Tax
Reassessment notice validity: extended notices without prescribed conditions or pre-reopening consultation are invalid and quashed.
February 26, 2026   Case Laws Income Tax
Reopening Assessments invalid where satisfaction and jurisdictional approval are absent for third party seized material, leading to quashing of assessment.
February 26, 2026   Case Laws Income Tax
Limitation under Section 153: period lost during handover of books is excluded; assessment beyond extended deadline is time-barred.
February 26, 2026   Case Laws Income Tax
Section 269SS cash receipt rule: recorded sale consideration and absent AO satisfaction or limitation can negate penalty under Section 271D.
February 26, 2026   Case Laws Income Tax
Trust purchase prohibition: tribunal found exemption preserved where sellers lacked substantial interest or control in the investee.

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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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