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    January 23, 2026   Case Laws Income Tax
    Reopening of income-tax assessment after search: computation of six-year and ten-year limitation periods renders older notice barred and quashed.
    January 23, 2026   Case Laws Income Tax
    International transaction characterisation of domestic divestment of support services business rejected; transaction between resident associated enter...
    January 23, 2026   Case Laws Income Tax
    Freight payment compliance and unrecorded cash evidence in tax assessment reviewed; additions deleted for lack of corroboration and verification
    January 23, 2026   Case Laws Income Tax
    TDS obligations on rental and legal fees: liability upheld for non-deduction on provisions, partial relief where TDS paid on actual payment.
    January 23, 2026   Case Laws Income Tax
    Jurisdiction to transfer under section 127 invalidates orders by non-jurisdictional AO, assessment orders quashed by ITAT
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    Assessment order in name of deceased assessee treated as irregular, rectifiable by bringing legal heirs on record under succession provisions
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    Levy of service tax on penal interest, notice pay and CSR sponsorship examined; sponsorship demands and penalties sustained in part.
    January 23, 2026   Case Laws Customs
    Minimum Import Price restrictions for Black Pepper, Areca-nuts and Apples upheld; procedural laying failure not fatal, notifications to be placed befo...
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    January 23, 2026   Case Laws Customs
    Classification of imported aluminium tubes, pipes and profiles: held under specific tariff headings, exemption granted and penalties quashed
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    January 23, 2026   Case Laws Customs
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    January 23, 2026   Case Laws Customs
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    January 23, 2026   Case Laws Customs
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    January 23, 2026   Case Laws Customs
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    January 23, 2026   Case Laws Customs
    Smuggling allegation of gold and proof of foreign origin requires positive evidence; failure to prove leads to dismissal
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January 23, 2026   Case Laws Income Tax
Reopening of income-tax assessment after search: computation of six-year and ten-year limitation periods renders older notice barred and quashed.
January 23, 2026   Case Laws Income Tax
International transaction characterisation of domestic divestment of support services business rejected; transaction between resident associated enterprises not deemed international, appeal allowed
January 23, 2026   Case Laws Income Tax
Freight payment compliance and unrecorded cash evidence in tax assessment reviewed; additions deleted for lack of corroboration and verification
January 23, 2026   Case Laws Income Tax
TDS obligations on rental and legal fees: liability upheld for non-deduction on provisions, partial relief where TDS paid on actual payment.
January 23, 2026   Case Laws Income Tax
Jurisdiction to transfer under section 127 invalidates orders by non-jurisdictional AO, assessment orders quashed by ITAT
January 23, 2026   Case Laws Income Tax
Penalty under section 271AAA on disclosure during search: relief granted where income was disclosed, explained and taxes paid
January 23, 2026   Case Laws Income Tax
Valuation of share premium and applicability to non-resident subscribers: rectification extinguishes addition and addition deleted on merits
January 23, 2026   Case Laws Income Tax
Assessment order in name of deceased assessee treated as irregular, rectifiable by bringing legal heirs on record under succession provisions
January 23, 2026   Case Laws Service Tax
Levy of service tax on penal interest, notice pay and CSR sponsorship examined; sponsorship demands and penalties sustained in part.
January 23, 2026   Case Laws Customs
Minimum Import Price restrictions for Black Pepper, Areca-nuts and Apples upheld; procedural laying failure not fatal, notifications to be placed before Parliament
January 23, 2026   Case Laws Customs
Transaction value between related persons requires market-equivalent pricing; importer must prove declared value mirrors ordinary international trade price.
January 23, 2026   Case Laws Customs
Classification of imported aluminium tubes, pipes and profiles: held under specific tariff headings, exemption granted and penalties quashed
January 23, 2026   Case Laws Customs
Imported food consignment cleared despite a rejection test report; confiscation and penalties set aside due to procedural lapses
January 23, 2026   Case Laws Customs
Classification of exported insecticides under export tariff affirmed; reclassification and related penalties set aside and MEIS scrip jurisdiction recognised
January 23, 2026   Case Laws Customs
Imports under Advance Authorisation challenged for pre-import condition failure; tribunal rejects revenues proof and quashes IGST penalties.
January 23, 2026   Case Laws Customs
Admissibility of computer printouts and statements under section 108 in customs valuation; reassessment and penalties set aside.
January 23, 2026   Case Laws Customs
Retroactive application of amended Explanation 4 to Section 28 bars adjudication of pre-amendment show cause notices, leading to vacatur.
January 23, 2026   Case Laws Customs
Classification of imported vitamin feed supplements as animal feed preparations affirmed, applying end-use and GRI 1 while limiting HSN reliance
January 23, 2026   Case Laws Customs
Liability for short-levied customs duty due to Customs House Agent misappropriation; importers bona fide demand draft payment negates duty.
January 23, 2026   Case Laws Customs
Smuggling allegation of gold and proof of foreign origin requires positive evidence; failure to prove leads to dismissal

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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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