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    January 13, 2026   Case Laws Income Tax
    Validity of unsigned Section 148 notice declared void; reassessment proceedings based on it held invalid, relief for assessee
    January 13, 2026   Case Laws Income Tax
    Penalty orders u/s 271E/271D-whether limitation u/s 275(1)(c) runs from Assessing Officer's reference; therefore orders time-barred
    January 13, 2026   Case Laws Income Tax
    Seized incriminating documents and receipts determining tax additions for student fees, property investment, and stamp duty - partly upheld
    January 13, 2026   Case Laws Income Tax
    Residential status u/s 6(1) Explanation 1(b): stays below 182 days for 2017-20, s.115C Explanation (e) confirms non-resident
    January 13, 2026   Case Laws Income Tax
    Assessment time-barred u/s 153 due to missing competent-authority reference for Singapore exchange of information; assessment disallowed as barred by ...
    January 13, 2026   Case Laws Income Tax
    Filing wrong ITR form (ITR-7 vs ITR-5) and disallowance of lawful business expenses; tribunal restores deductions, orders refiling and reassessment
    January 13, 2026   Case Laws Income Tax
    AMP payments and marketing salaries via credit-notes found genuine; disallowances deleted; no AMP reallocation; 14A limited
    January 13, 2026   Case Laws Income Tax
    Proprietary software held by taxpayer treated as intangible asset eligible for 60% depreciation allowance, overturning 25% limit
    January 13, 2026   Case Laws Income Tax
    Claiming new tax regime after late Form 10-IE and delayed return: new-regime election infirm; verification ordered and relief possible.
    January 13, 2026   Case Laws Customs
    Imported menthol-scented sweet supari classification dispute: seizure quashed, release for home consumption subject to duty bond; bank guarantee refus...
    January 13, 2026   Case Laws Customs
    Imported fabric thickness discrepancy valuation fixed by contemporaneous imports at US$1.80/m, duties and penalties upheld.
    January 13, 2026   Case Laws Customs
    Classification of product as organic surface-active agent (surfactant) under CTH 3402; held classifiable at CTH 3402 4200 pending import verification
    January 13, 2026   Case Laws Service Tax
    Reimbursements to foreign representative office treated as mere expense recovery, not taxable consideration under reverse-charge; order set aside
    January 13, 2026   Case Laws Service Tax
    Appellants' receipts characterized as taxable services u/s 65B; liability sustained, one receipt exempted; extended limitation not invoked
    January 13, 2026   Case Laws Customs
    CKD/SKD air-conditioner components classifiable with finished units by essential character; prior advance ruling extended three years, FTA benefits po...
    January 13, 2026   Case Laws IBC
    Jurisdiction of arbitral tribunal over claim after approval of resolution plan found absent; award set aside and proceedings terminated
    January 13, 2026   Case Laws IBC
    Scope of judicial review under Article 226: supervisory, not appellate; factual reappraisal barred, challenge dismissed; insolvency professional dutie...
    January 13, 2026   Case Laws IBC
    Unpaid supply of 346 units held operational debt; default established and Section 9/CIRP admission upheld after no bona fide dispute
    January 13, 2026   Case Laws Service Tax
    Development-agreement land transfers found to be transfers of ownership not taxable; extended limitation inapplicable without wilful concealment
    January 13, 2026   Case Laws Central Excise
    Refilling gas into customer-supplied cylinders found not "manufacture" under deeming provision; excise demand set aside
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January 13, 2026   Case Laws Income Tax
Validity of unsigned Section 148 notice declared void; reassessment proceedings based on it held invalid, relief for assessee
January 13, 2026   Case Laws Income Tax
Penalty orders u/s 271E/271D-whether limitation u/s 275(1)(c) runs from Assessing Officer's reference; therefore orders time-barred
January 13, 2026   Case Laws Income Tax
Seized incriminating documents and receipts determining tax additions for student fees, property investment, and stamp duty - partly upheld
January 13, 2026   Case Laws Income Tax
Residential status u/s 6(1) Explanation 1(b): stays below 182 days for 2017-20, s.115C Explanation (e) confirms non-resident
January 13, 2026   Case Laws Income Tax
Assessment time-barred u/s 153 due to missing competent-authority reference for Singapore exchange of information; assessment disallowed as barred by limitation
January 13, 2026   Case Laws Income Tax
Filing wrong ITR form (ITR-7 vs ITR-5) and disallowance of lawful business expenses; tribunal restores deductions, orders refiling and reassessment
January 13, 2026   Case Laws Income Tax
AMP payments and marketing salaries via credit-notes found genuine; disallowances deleted; no AMP reallocation; 14A limited
January 13, 2026   Case Laws Income Tax
Proprietary software held by taxpayer treated as intangible asset eligible for 60% depreciation allowance, overturning 25% limit
January 13, 2026   Case Laws Income Tax
Claiming new tax regime after late Form 10-IE and delayed return: new-regime election infirm; verification ordered and relief possible.
January 13, 2026   Case Laws Customs
Imported menthol-scented sweet supari classification dispute: seizure quashed, release for home consumption subject to duty bond; bank guarantee refused
January 13, 2026   Case Laws Customs
Imported fabric thickness discrepancy valuation fixed by contemporaneous imports at US$1.80/m, duties and penalties upheld.
January 13, 2026   Case Laws Customs
Classification of product as organic surface-active agent (surfactant) under CTH 3402; held classifiable at CTH 3402 4200 pending import verification
January 13, 2026   Case Laws Service Tax
Reimbursements to foreign representative office treated as mere expense recovery, not taxable consideration under reverse-charge; order set aside
January 13, 2026   Case Laws Service Tax
Appellants' receipts characterized as taxable services u/s 65B; liability sustained, one receipt exempted; extended limitation not invoked
January 13, 2026   Case Laws Customs
CKD/SKD air-conditioner components classifiable with finished units by essential character; prior advance ruling extended three years, FTA benefits possible
January 13, 2026   Case Laws IBC
Jurisdiction of arbitral tribunal over claim after approval of resolution plan found absent; award set aside and proceedings terminated
January 13, 2026   Case Laws IBC
Scope of judicial review under Article 226: supervisory, not appellate; factual reappraisal barred, challenge dismissed; insolvency professional duties upheld
January 13, 2026   Case Laws IBC
Unpaid supply of 346 units held operational debt; default established and Section 9/CIRP admission upheld after no bona fide dispute
January 13, 2026   Case Laws Service Tax
Development-agreement land transfers found to be transfers of ownership not taxable; extended limitation inapplicable without wilful concealment
January 13, 2026   Case Laws Central Excise
Refilling gas into customer-supplied cylinders found not "manufacture" under deeming provision; excise demand set aside

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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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Acts Income Tax
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