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    February 26, 2026   Case Laws Income Tax
    Service of assessment order failed due to e filing upload error and no proof of postal service, resulting in appeal allowed.
    February 26, 2026   Case Laws Income Tax
    Transfer Pricing Comparable Selection: specified comparables ordered included, one excluded for functional dissimilarity and ECB interest deleted.
    February 26, 2026   Case Laws Income Tax
    Possession as transfer: acquisition year fixed for CII and construction-cost deduction allowed by parity with co owners.
    February 26, 2026   Case Laws Benami Property
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    February 26, 2026   Case Laws Customs
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    February 26, 2026   Case Laws Companies Law
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    February 26, 2026   Case Laws IBC
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    February 25, 2026   Notifications DGFT
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    February 25, 2026   Circulars DGFT
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February 26, 2026   Case Laws Income Tax
Service of assessment order failed due to e filing upload error and no proof of postal service, resulting in appeal allowed.
February 26, 2026   Case Laws Income Tax
Transfer Pricing Comparable Selection: specified comparables ordered included, one excluded for functional dissimilarity and ECB interest deleted.
February 26, 2026   Case Laws Income Tax
Possession as transfer: acquisition year fixed for CII and construction-cost deduction allowed by parity with co owners.
February 26, 2026   Case Laws Benami Property
Benami property exclusion from the insolvency estate: Benami Act proceedings preclude IBC tribunals from reopening attachments or treating such assets as estate property.
February 26, 2026   Case Laws Customs
Issue Estoppel limits appellate re examination; appellate authority cannot revisit its appellate order when granting consequential relief.
February 26, 2026   Case Laws Customs
Verification of origin and provisional release: court permits provisional release against bank guarantee while origin verification proceeds.
February 26, 2026   Case Laws Customs
Interest on delayed refunds runs from the day after three months of the refund application, irrespective of later sanction.
February 26, 2026   Case Laws Companies Law
Joinder and amendment of pleadings secure the right to adjudication on merits by permitting rectification of the cause title.
February 26, 2026   Case Laws IBC
Transactions During Moratorium: restoration of unauthorised receipts to the liquidation estate upheld despite belated criminal allegations.
February 26, 2026   Case Laws IBC
Exclusion of limitation period: pandemic suspension plus debtor acknowledgement can extend limitation, requiring fresh factfinding on guarantee invocation.
February 26, 2026   Case Laws IBC
Default on interest triggers acceleration of debt and permits admission of insolvency petition; further tribunal proceedings directed.
February 26, 2026   Case Laws FEMA
Retraction of confession rejected where delayed and uncorroborated; corroboration sustained, confiscation upheld and penalty reduced.
February 26, 2026   Case Laws FEMA
Continuing Liability of Struck Off Companies persists; pre deposit noncompliance sustains penalty and appellate reduction may adjust individual fines.
February 26, 2026   Case Laws Money Laundering
Definition of proceeds of crime requires nexus to a scheduled offence; absence of prima facie nexus supported grant of bail.
February 26, 2026   Case Laws Money Laundering
Burden of proof in provisional attachment: failure to prove lawful sources upheld and attachment sustained.
February 25, 2026   Notifications DGFT
Export policy amendment for wheat permits limited authorised exports while retaining food security exemptions and separate modalities.
February 25, 2026   Notifications DGFT
Export restriction on wheat flour eased to allow a limited additional export allocation, subject to DGFT modalities.
February 25, 2026   Notifications SEZ
De-notification of SEZ land permits repurposing a parcel for infrastructure while retaining SEZ area under SEZ Act procedures.
February 25, 2026   Circulars DGFT
Tariff Rate Quota deadline extended: TRQ applications for specified FTAs must be filed by 15 March 2026.
February 25, 2026   Circulars DGFT
Export Authorization for Wheat: online monthly application window, non-transferable six-month authorisations subject to Special EFC allocation.

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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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