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    February 3, 2026   Case Laws Income Tax
    Penalty under Section 271(1)(c) requires notice specificity between concealment and inaccurate particulars; failure invalidates the penalty.
    February 3, 2026   Case Laws Income Tax
    Penalty initiation after unexplained income additions must be prima facie examined; revision under section 263 upheld
    February 3, 2026   Case Laws Income Tax
    Entitlement to deduction under section 80P(2)(d) challenged, but assessing officer's plausible view sustained and revision powers denied.
    February 3, 2026   Case Laws Customs
    Concessional Basic Customs Duty on Ethernet switches: classification as enterprise switches upheld, challenge dismissed for lack of substantial law qu...
    February 3, 2026   Case Laws Customs
    Use of imported helicopter contrary to exemption undertaking leads to confiscation; individual penalties set aside for lack of knowledge.
    February 3, 2026   Case Laws Service Tax
    Condonation of delay in filing appeals limited to thirty days; Commissioner denial upholds dismissal of delayed filing.
    February 3, 2026   Case Laws IBC
    Fraudulent trading and wrongful trading under IBC found on false accounting; appeal dismissed and contribution ordered.
    February 3, 2026   Case Laws IBC
    Insolvency petition based on admitted debt and default upheld; challenge for malicious initiation rejected, settlement may proceed under resolution fr...
    February 3, 2026   Case Laws Money Laundering
    Legality of arrest under PMLA challenged over material and procedure, but court affirmed procedural compliance and dismissed petitions
    February 3, 2026   Case Laws Money Laundering
    Quashing of FIR and challenge to ECIR over alleged diversion of funds and preferential ESOP pricing dismissed after prima facie money-laundering findi...
    February 3, 2026   Case Laws Money Laundering
    Proceeds of crime and attachment of property of equivalent value upheld where original proceeds are not traceable, appeal dismissed
    February 3, 2026   Case Laws Central Excise
    Roasting of Rava/Suji found not to be manufacture; no excise duty on roasting, appeal allowed.
    February 3, 2026   Case Laws Indian Laws
    Director liability under negotiable instruments: documentary indicia can sustain summoning, but recorded resignation can secure discharge.
    February 3, 2026   Case Laws Indian Laws
    Dishonour of cheque: presumption under negotiable instruments act upheld; acquittal set aside and conviction with fine imposed
    February 2, 2026   Case Laws GST
    Service of notice on GST portal and denial of personal hearing; writ dismissed as statutory appellate remedy is available
    February 2, 2026   Case Laws GST
    Summons during GST investigation treated as inquiry evidence-gathering, so anticipatory relief was premature and writ dismissed
    February 2, 2026   Case Laws GST
    Reversal of Input Tax Credit claims based on GST portal returns; orders set aside and remanded for fresh adjudication.
    February 2, 2026   Case Laws GST
    Violation of natural justice in GST adjudication: personal hearing details and reasoned orders required, petition allowed
    February 2, 2026   Case Laws GST
    Limitation in statutory appeals under CGST section 107(4): appellate one-month extension only; writ challenging show-cause rejected.
    February 2, 2026   Case Laws GST
    Determination of tax liability and input tax credit recovery where agent filed returns; writ dismissed, appeal available to taxpayer.
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February 3, 2026   Case Laws Income Tax
Penalty under Section 271(1)(c) requires notice specificity between concealment and inaccurate particulars; failure invalidates the penalty.
February 3, 2026   Case Laws Income Tax
Penalty initiation after unexplained income additions must be prima facie examined; revision under section 263 upheld
February 3, 2026   Case Laws Income Tax
Entitlement to deduction under section 80P(2)(d) challenged, but assessing officer's plausible view sustained and revision powers denied.
February 3, 2026   Case Laws Customs
Concessional Basic Customs Duty on Ethernet switches: classification as enterprise switches upheld, challenge dismissed for lack of substantial law question
February 3, 2026   Case Laws Customs
Use of imported helicopter contrary to exemption undertaking leads to confiscation; individual penalties set aside for lack of knowledge.
February 3, 2026   Case Laws Service Tax
Condonation of delay in filing appeals limited to thirty days; Commissioner denial upholds dismissal of delayed filing.
February 3, 2026   Case Laws IBC
Fraudulent trading and wrongful trading under IBC found on false accounting; appeal dismissed and contribution ordered.
February 3, 2026   Case Laws IBC
Insolvency petition based on admitted debt and default upheld; challenge for malicious initiation rejected, settlement may proceed under resolution framework
February 3, 2026   Case Laws Money Laundering
Legality of arrest under PMLA challenged over material and procedure, but court affirmed procedural compliance and dismissed petitions
February 3, 2026   Case Laws Money Laundering
Quashing of FIR and challenge to ECIR over alleged diversion of funds and preferential ESOP pricing dismissed after prima facie money-laundering findings
February 3, 2026   Case Laws Money Laundering
Proceeds of crime and attachment of property of equivalent value upheld where original proceeds are not traceable, appeal dismissed
February 3, 2026   Case Laws Central Excise
Roasting of Rava/Suji found not to be manufacture; no excise duty on roasting, appeal allowed.
February 3, 2026   Case Laws Indian Laws
Director liability under negotiable instruments: documentary indicia can sustain summoning, but recorded resignation can secure discharge.
February 3, 2026   Case Laws Indian Laws
Dishonour of cheque: presumption under negotiable instruments act upheld; acquittal set aside and conviction with fine imposed
February 2, 2026   Case Laws GST
Service of notice on GST portal and denial of personal hearing; writ dismissed as statutory appellate remedy is available
February 2, 2026   Case Laws GST
Summons during GST investigation treated as inquiry evidence-gathering, so anticipatory relief was premature and writ dismissed
February 2, 2026   Case Laws GST
Reversal of Input Tax Credit claims based on GST portal returns; orders set aside and remanded for fresh adjudication.
February 2, 2026   Case Laws GST
Violation of natural justice in GST adjudication: personal hearing details and reasoned orders required, petition allowed
February 2, 2026   Case Laws GST
Limitation in statutory appeals under CGST section 107(4): appellate one-month extension only; writ challenging show-cause rejected.
February 2, 2026   Case Laws GST
Determination of tax liability and input tax credit recovery where agent filed returns; writ dismissed, appeal available to taxpayer.

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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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