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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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Income Tax

Functional comparability is essential in transfer pricing...

Functional comparability in transfer pricing excludes government-owned and diversified service providers lacking reliable segmental data.

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Income Tax March 28, 2026 Case Laws AT
Functional comparability is essential in transfer pricing analysis, and a government-owned enterprise with broader consultancy and project execution functions cannot be compared with a captive technical support provider. HSCC India Ltd. was excluded because it rendered comprehensive health-sector consultancy, served government ministries and agencies, and enjoyed advantages flowing from its governmental character; the absence of a subsidy did not make it comparable. Mitcon Consultancy and Engineering Services Ltd. was also excluded because it had diversified operations across multiple sectors and lacked reliable segmental revenue data in its signed accounts, making a valid comparison impossible. The assessee's appeal was allowed and the transfer pricing exercise was to proceed after excluding both entities.
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Acts Income Tax
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