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    February 24, 2026   Circulars DGFT
    Overseas Warehousing Support under an export mission provides time bound subsidised operational costs with monitoring and recovery conditions.
    February 24, 2026   Case Laws GST
    Alternative remedy of appeal must be exhausted; appellate authority has wider inquiry powers, writ dismissed in absence of prejudice.
    February 24, 2026   Case Laws GST
    Cancellation of GST registration: furnishing pending returns and full tax payment enables restoration if the officer finds compliance.
    February 24, 2026   Case Laws GST
    Cancellation of GST Registration: restoration permitted on filing pending returns and full payment; limitation computed from this order.
    February 24, 2026   Case Laws GST
    Provisional release is statutory: release on payment in lieu of confiscation applies only after a final confiscation order.
    February 24, 2026   Case Laws GST
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    February 24, 2026   Case Laws Income Tax
    FTS and Royalty classification determines applicability of exploration-specific tax rule; remand ordered to reassess withholding certificate.
    February 24, 2026   Case Laws Income Tax
    Capital Gains characterization upheld: unlisted preference shares treated as capital gains and revision under revisional jurisdiction set aside.
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    Refund entitlement: administrative remittal for inquiry and decision, with notice and duty to consider supporting records.
    February 24, 2026   Case Laws Income Tax
    Capital Asset transfer in redevelopment: indexed cost applies to the whole property and residential reinvestment deduction allowed.
    February 24, 2026   Case Laws Income Tax
    Failure to claim deduction in return bars 80JJAA relief; statutory non compliance with filing requirements led to disallowance.
    February 24, 2026   Case Laws Income Tax
    Beneficial owner determination under GPA negates capital gains liability; fuel, bonus and TDS additions reconsidered and adjusted.
    February 24, 2026   Case Laws Income Tax
    Revision under section 263: AO's inquiries and merchant banker DCF valuation upheld, reversing revisionary interference against assessee.
    February 24, 2026   Case Laws Income Tax
    Admission and Documentary Corroboration supported reassessment; prima facie material justified taxing alleged unaccounted cash consideration.
    February 24, 2026   Case Laws Income Tax
    Perquisite taxation: employer-paid annuity contributions are not taxable until the employee acquires a vested right to annuity receipts.
    February 24, 2026   Case Laws Income Tax
    Mechanical approval invalidates reopening of assessment where the approving officer fails to record reasons, so notice and reassessment were quashed.
    February 24, 2026   Case Laws Income Tax
    Deduction under 80IA: apportion common salary between power and trading by turnover and recompute the deduction.
    February 24, 2026   Case Laws Income Tax
    Eligibility for deduction under section 80-IAB: co-developer status under SEZ Act qualifies, deduction allowed subject to verification.
    February 24, 2026   Case Laws Income Tax
    Condonation of Delay denied: communication lapses and corporate restructuring found insufficient; prolonged inaction and lack of bona fides led to ref...
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February 24, 2026   Circulars DGFT
Overseas Warehousing Support under an export mission provides time bound subsidised operational costs with monitoring and recovery conditions.
February 24, 2026   Case Laws GST
Alternative remedy of appeal must be exhausted; appellate authority has wider inquiry powers, writ dismissed in absence of prejudice.
February 24, 2026   Case Laws GST
Cancellation of GST registration: furnishing pending returns and full tax payment enables restoration if the officer finds compliance.
February 24, 2026   Case Laws GST
Cancellation of GST Registration: restoration permitted on filing pending returns and full payment; limitation computed from this order.
February 24, 2026   Case Laws GST
Provisional release is statutory: release on payment in lieu of confiscation applies only after a final confiscation order.
February 24, 2026   Case Laws GST
Right to be heard: deficient portal service of show-cause notices warrants remand and fresh personal hearings with replies considered.
February 24, 2026   Case Laws GST
Profiteering and Input Tax Credit: balance refund and interest to remaining buyers required within 30 days.
February 24, 2026   Case Laws Income Tax
FTS and Royalty classification determines applicability of exploration-specific tax rule; remand ordered to reassess withholding certificate.
February 24, 2026   Case Laws Income Tax
Capital Gains characterization upheld: unlisted preference shares treated as capital gains and revision under revisional jurisdiction set aside.
February 24, 2026   Case Laws Income Tax
Refund entitlement: administrative remittal for inquiry and decision, with notice and duty to consider supporting records.
February 24, 2026   Case Laws Income Tax
Capital Asset transfer in redevelopment: indexed cost applies to the whole property and residential reinvestment deduction allowed.
February 24, 2026   Case Laws Income Tax
Failure to claim deduction in return bars 80JJAA relief; statutory non compliance with filing requirements led to disallowance.
February 24, 2026   Case Laws Income Tax
Beneficial owner determination under GPA negates capital gains liability; fuel, bonus and TDS additions reconsidered and adjusted.
February 24, 2026   Case Laws Income Tax
Revision under section 263: AO's inquiries and merchant banker DCF valuation upheld, reversing revisionary interference against assessee.
February 24, 2026   Case Laws Income Tax
Admission and Documentary Corroboration supported reassessment; prima facie material justified taxing alleged unaccounted cash consideration.
February 24, 2026   Case Laws Income Tax
Perquisite taxation: employer-paid annuity contributions are not taxable until the employee acquires a vested right to annuity receipts.
February 24, 2026   Case Laws Income Tax
Mechanical approval invalidates reopening of assessment where the approving officer fails to record reasons, so notice and reassessment were quashed.
February 24, 2026   Case Laws Income Tax
Deduction under 80IA: apportion common salary between power and trading by turnover and recompute the deduction.
February 24, 2026   Case Laws Income Tax
Eligibility for deduction under section 80-IAB: co-developer status under SEZ Act qualifies, deduction allowed subject to verification.
February 24, 2026   Case Laws Income Tax
Condonation of Delay denied: communication lapses and corporate restructuring found insufficient; prolonged inaction and lack of bona fides led to refusal.

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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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