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    January 20, 2026   Case Laws GST
    Jurisdiction to issue show-cause notice u/s74 CGST/MGST after para 2 of Notification No.11/2017 struck down; reply affidavit ordered
    January 20, 2026   Case Laws Income Tax
    Verification of claimed TDS credits by assessing officers must precede waiver; directions to modify tax software set aside
    January 20, 2026   Case Laws Income Tax
    Reconciled challan tax credits and return of seized cash with interest ordered to be refunded within 30 days
    January 20, 2026   Case Laws Income Tax
    Requirement of recorded satisfaction before Section 14A/Rule 8D disallowance of claimed expenditure; addition invalidated on that ground
    January 20, 2026   Case Laws Income Tax
    Revisional order directing initiation of penalty u/s271E without Assessing Officer's recorded satisfaction set aside on appeal
    January 20, 2026   Case Laws Income Tax
    Interest on enhanced compensation held taxable u/s56(2)(viii) read with s.145B(1); s.10(37) exemption denied, revision u/s263 upheld
    January 20, 2026   Case Laws Income Tax
    Straight-line lease rental accounting change results in penalty quashed where disclosed accounts and bona fide arguable accounting interpretation exis...
    January 20, 2026   Case Laws Income Tax
    Distributor's activities under distribution agreement not a dependent-agent permanent establishment; software/training payments taxed as FTS
    January 20, 2026   Case Laws Income Tax
    Alleged bogus purchases, unexplained expenditure and trial-balance gross-profit adjustments held unsupported; assessment additions deleted for taxpaye...
    January 20, 2026   Case Laws Income Tax
    Cross-border receipts for flight data, software licences and services not "royalty" under Article 12 DTAA; treated as business income
    January 20, 2026   Case Laws Income Tax
    Allocation of enhanced FSI/TDR proceeds between cooperative society and individual flat-owners; tribunal deletes society LTCG addition, remits 80P ver...
    January 20, 2026   Case Laws Income Tax
    Non-maintenance of item-wise/month-wise stock registers not valid ground to reject audited books; gross profit uplift deleted u/s145
    January 20, 2026   Case Laws Income Tax
    Charitable trust investments in trustee-interested partnership breach prescribed investment mode, exemption disallowed and income taxed at top rate
    January 20, 2026   Case Laws Indian Laws
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    January 20, 2026   Case Laws Income Tax
    Deduction for interest and dividends from co-operative banks upheld where AO's plausible view prevents revisionary jurisdiction; appeal allowed.
    January 20, 2026   Case Laws Customs
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    January 20, 2026   Case Laws Customs
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    January 20, 2026   Case Laws Customs
    Import clearance broker authorization upheld; alleged Customs breaches on lithium markings, due diligence and KYC rejected, order set aside
    January 20, 2026   Case Laws Customs
    Processed betel-nut supari classification as CTH 2106 90 30, qualifying for Notification No. 68/2012 exemption
    January 20, 2026   Case Laws Money Laundering
    Double jeopardy and PMLA money-laundering allegations where earlier ECIR trial pending - prosecution allowed; regular bail refused
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January 20, 2026   Case Laws GST
Jurisdiction to issue show-cause notice u/s74 CGST/MGST after para 2 of Notification No.11/2017 struck down; reply affidavit ordered
January 20, 2026   Case Laws Income Tax
Verification of claimed TDS credits by assessing officers must precede waiver; directions to modify tax software set aside
January 20, 2026   Case Laws Income Tax
Reconciled challan tax credits and return of seized cash with interest ordered to be refunded within 30 days
January 20, 2026   Case Laws Income Tax
Requirement of recorded satisfaction before Section 14A/Rule 8D disallowance of claimed expenditure; addition invalidated on that ground
January 20, 2026   Case Laws Income Tax
Revisional order directing initiation of penalty u/s271E without Assessing Officer's recorded satisfaction set aside on appeal
January 20, 2026   Case Laws Income Tax
Interest on enhanced compensation held taxable u/s56(2)(viii) read with s.145B(1); s.10(37) exemption denied, revision u/s263 upheld
January 20, 2026   Case Laws Income Tax
Straight-line lease rental accounting change results in penalty quashed where disclosed accounts and bona fide arguable accounting interpretation existed
January 20, 2026   Case Laws Income Tax
Distributor's activities under distribution agreement not a dependent-agent permanent establishment; software/training payments taxed as FTS
January 20, 2026   Case Laws Income Tax
Alleged bogus purchases, unexplained expenditure and trial-balance gross-profit adjustments held unsupported; assessment additions deleted for taxpayer
January 20, 2026   Case Laws Income Tax
Cross-border receipts for flight data, software licences and services not "royalty" under Article 12 DTAA; treated as business income
January 20, 2026   Case Laws Income Tax
Allocation of enhanced FSI/TDR proceeds between cooperative society and individual flat-owners; tribunal deletes society LTCG addition, remits 80P verification
January 20, 2026   Case Laws Income Tax
Non-maintenance of item-wise/month-wise stock registers not valid ground to reject audited books; gross profit uplift deleted u/s145
January 20, 2026   Case Laws Income Tax
Charitable trust investments in trustee-interested partnership breach prescribed investment mode, exemption disallowed and income taxed at top rate
January 20, 2026   Case Laws Indian Laws
Erstwhile directors' liability for cheque dishonour after IRP appointment u/s 138 - summoning quashed, complaint dismissed
January 20, 2026   Case Laws Income Tax
Deduction for interest and dividends from co-operative banks upheld where AO's plausible view prevents revisionary jurisdiction; appeal allowed.
January 20, 2026   Case Laws Customs
Provisional release of imported goods: 100% bank guarantee deemed excessive; reduced to 50% of estimated differential duty
January 20, 2026   Case Laws Customs
Foreign-origin cigarettes found in seized vehicle - appellant not liable u/ss 112(a), 112(b); penalties annulled; concealment goods forfeited
January 20, 2026   Case Laws Customs
Import clearance broker authorization upheld; alleged Customs breaches on lithium markings, due diligence and KYC rejected, order set aside
January 20, 2026   Case Laws Customs
Processed betel-nut supari classification as CTH 2106 90 30, qualifying for Notification No. 68/2012 exemption
January 20, 2026   Case Laws Money Laundering
Double jeopardy and PMLA money-laundering allegations where earlier ECIR trial pending - prosecution allowed; regular bail refused

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Home › Highlights › Income Tax › 2026 › March, 2026 › This
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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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