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    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
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    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
    January 13, 2026   Case Laws Central Excise
    Eligibility for CENVAT refund u/r 5 and jurisdictional overlap: earlier Commissioner's non-original order quashed; cases remanded
    January 13, 2026   Case Laws Indian Laws
    Multiple cheques for same debt and alleged duplicate complaints: quashing u/s 482 rejected; Section 138 case restored.
    January 13, 2026   Case Laws Indian Laws
    Non-executive director's role in borrower default dispute under RBI Master Circular Clause 3(d); wilful defaulter tag removed.
    January 13, 2026   Case Laws Indian Laws
    Blank security cheques from guarantors in third-party loan dispute: enforceable debt questioned; cheque dishonour conviction set aside.
    January 12, 2026   Circulars DGFT
    India-Arab Chamber authorised to issue non-preferential Certificates of Origin for export shipments under Foreign Trade Policy 2023
    January 12, 2026   Circulars DGFT
    eBRC format updated to capture GSTIN and GST invoice details; revised Appendix 2U mandatory for eBRCs from 13 Jan 2026
    January 12, 2026   Circulars SEBI
    AIF investor accreditation delays scheme corpus counting; managers may sign contribution agreements, accept funds only after certificate issued
    January 12, 2026   Circulars Customs
    Courier transshipment of imported goods via named carrier to air cargo stations renewed until 30.01.2026; exemption conditional, strict controls apply...
    January 12, 2026   Circulars Customs
    Transshipment of imported courier goods from new terminal to nominated air cargo ports allowed, with bonds and strict procedures
    January 12, 2026   Circulars Customs
    Five-year renewal of imported cargo custodianship u/s 45(1), with bonds, insurance and strict handling compliance conditions
    January 12, 2026   Case Laws Income Tax
    Residential status and India-Singapore DTAA tie-breaker for AY 2020-21: s.6(1)(c) thresholds met, resident upheld
    January 12, 2026   Case Laws Income Tax
    Delay in remitting TDS under s. 276B-maternity leave staff shortage cited as reasonable cause; prosecution quashed, challenge dismissed.
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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
January 13, 2026   Case Laws Central Excise
Eligibility for CENVAT refund u/r 5 and jurisdictional overlap: earlier Commissioner's non-original order quashed; cases remanded
January 13, 2026   Case Laws Indian Laws
Multiple cheques for same debt and alleged duplicate complaints: quashing u/s 482 rejected; Section 138 case restored.
January 13, 2026   Case Laws Indian Laws
Non-executive director's role in borrower default dispute under RBI Master Circular Clause 3(d); wilful defaulter tag removed.
January 13, 2026   Case Laws Indian Laws
Blank security cheques from guarantors in third-party loan dispute: enforceable debt questioned; cheque dishonour conviction set aside.
January 12, 2026   Circulars DGFT
India-Arab Chamber authorised to issue non-preferential Certificates of Origin for export shipments under Foreign Trade Policy 2023
January 12, 2026   Circulars DGFT
eBRC format updated to capture GSTIN and GST invoice details; revised Appendix 2U mandatory for eBRCs from 13 Jan 2026
January 12, 2026   Circulars SEBI
AIF investor accreditation delays scheme corpus counting; managers may sign contribution agreements, accept funds only after certificate issued
January 12, 2026   Circulars Customs
Courier transshipment of imported goods via named carrier to air cargo stations renewed until 30.01.2026; exemption conditional, strict controls apply.
January 12, 2026   Circulars Customs
Transshipment of imported courier goods from new terminal to nominated air cargo ports allowed, with bonds and strict procedures
January 12, 2026   Circulars Customs
Five-year renewal of imported cargo custodianship u/s 45(1), with bonds, insurance and strict handling compliance conditions
January 12, 2026   Case Laws Income Tax
Residential status and India-Singapore DTAA tie-breaker for AY 2020-21: s.6(1)(c) thresholds met, resident upheld
January 12, 2026   Case Laws Income Tax
Delay in remitting TDS under s. 276B-maternity leave staff shortage cited as reasonable cause; prosecution quashed, challenge dismissed.

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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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