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    February 16, 2026   Case Laws Income Tax
    Dispute Resolution Panel directions under Section 144C cannot address objections after a final assessment; appeal must proceed uninfluenced.
    February 16, 2026   Case Laws Income Tax
    Jurisdictional validity of reopening notices: writ relief allowed where notice issued without AO jurisdiction, notice set aside.
    February 16, 2026   Case Laws Income Tax
    Tax Treaty Relief upheld: nil-rate certificate ordered, with procedural directions for future applications and PE findings.
    February 16, 2026   Case Laws Income Tax
    Reopening of assessment: AO must form independent subjective satisfaction; reliance solely on audit opinions invalidates reassessment.
    February 16, 2026   Case Laws Income Tax
    Business expense deductibility for independent contractor services upheld, allowing marketing and MIS contract costs when bona fide and reasonable.
    February 16, 2026   Case Laws Income Tax
    Gifts from Relatives accepted as genuine with identifying particulars; cash professional fees and partnership withdrawals accepted, additions deleted.
    February 16, 2026   Case Laws Income Tax
    Jurisdictional defect: assessment by a non jurisdictional officer is void ab initio, so the assessment was quashed.
    February 16, 2026   Case Laws Income Tax
    Penalty for inaccurate particulars denied where voluntary disclosure and bona fide DTAA difference of opinion removed liability.
    February 16, 2026   Case Laws Income Tax
    Venture capital undertaking eligibility under SEBI VCF Regulations affirmed, enabling tax exemption for qualifying fund investments.
    February 16, 2026   Case Laws Income Tax
    Found in the course of search: seized documents from others can support a 153A assessment, but absence of incriminating material voids it.
    February 16, 2026   Case Laws Income Tax
    Tax Deduction at Source liability: payer not in default if payee paid tax; interest payable until payee files return.
    February 16, 2026   Case Laws Income Tax
    Concessional tax regime entitlement upheld despite late return filing where option form was filed within the prescribed period; benefit granted.
    February 16, 2026   Case Laws Benami Property
    Benami Transaction: fiduciary exemption rejected where no trust relationship, leading to attachment and confirmation of disputed properties.
    February 16, 2026   Case Laws Customs
    Ministerial certificate for import grade binds other importers, enabling challenge to redemption fine and personal penalty.
    February 16, 2026   Case Laws Customs
    Regulatory time limit for disciplinary orders: missing 90 day deadline led to revocation order being set aside.
    February 16, 2026   Case Laws Customs
    Admissibility of inquiry statements: such statements require formal examination and admission before the adjudicating authority, or they are inadmissi...
    February 16, 2026   Case Laws Customs
    Exemption from Integrated Tax: Notification No.45/2017-Cus covers IGST, and denials of that exemption were set aside.
    February 16, 2026   Case Laws IBC
    Financial debt characterization: share subscription money excluded as deposit, so insolvency petition was not maintainable.
    February 16, 2026   Case Laws IBC
    Invocation of guarantee: Form B demand notice does not substitute prior invocation; no default absent prior invocation, petition set aside.
    February 16, 2026   Case Laws IBC
    Pre-existing contractual disputes can bar CIRP admission if substantial and bona fide; liquidated damages require full adjudication.
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February 16, 2026   Case Laws Income Tax
Dispute Resolution Panel directions under Section 144C cannot address objections after a final assessment; appeal must proceed uninfluenced.
February 16, 2026   Case Laws Income Tax
Jurisdictional validity of reopening notices: writ relief allowed where notice issued without AO jurisdiction, notice set aside.
February 16, 2026   Case Laws Income Tax
Tax Treaty Relief upheld: nil-rate certificate ordered, with procedural directions for future applications and PE findings.
February 16, 2026   Case Laws Income Tax
Reopening of assessment: AO must form independent subjective satisfaction; reliance solely on audit opinions invalidates reassessment.
February 16, 2026   Case Laws Income Tax
Business expense deductibility for independent contractor services upheld, allowing marketing and MIS contract costs when bona fide and reasonable.
February 16, 2026   Case Laws Income Tax
Gifts from Relatives accepted as genuine with identifying particulars; cash professional fees and partnership withdrawals accepted, additions deleted.
February 16, 2026   Case Laws Income Tax
Jurisdictional defect: assessment by a non jurisdictional officer is void ab initio, so the assessment was quashed.
February 16, 2026   Case Laws Income Tax
Penalty for inaccurate particulars denied where voluntary disclosure and bona fide DTAA difference of opinion removed liability.
February 16, 2026   Case Laws Income Tax
Venture capital undertaking eligibility under SEBI VCF Regulations affirmed, enabling tax exemption for qualifying fund investments.
February 16, 2026   Case Laws Income Tax
Found in the course of search: seized documents from others can support a 153A assessment, but absence of incriminating material voids it.
February 16, 2026   Case Laws Income Tax
Tax Deduction at Source liability: payer not in default if payee paid tax; interest payable until payee files return.
February 16, 2026   Case Laws Income Tax
Concessional tax regime entitlement upheld despite late return filing where option form was filed within the prescribed period; benefit granted.
February 16, 2026   Case Laws Benami Property
Benami Transaction: fiduciary exemption rejected where no trust relationship, leading to attachment and confirmation of disputed properties.
February 16, 2026   Case Laws Customs
Ministerial certificate for import grade binds other importers, enabling challenge to redemption fine and personal penalty.
February 16, 2026   Case Laws Customs
Regulatory time limit for disciplinary orders: missing 90 day deadline led to revocation order being set aside.
February 16, 2026   Case Laws Customs
Admissibility of inquiry statements: such statements require formal examination and admission before the adjudicating authority, or they are inadmissible.
February 16, 2026   Case Laws Customs
Exemption from Integrated Tax: Notification No.45/2017-Cus covers IGST, and denials of that exemption were set aside.
February 16, 2026   Case Laws IBC
Financial debt characterization: share subscription money excluded as deposit, so insolvency petition was not maintainable.
February 16, 2026   Case Laws IBC
Invocation of guarantee: Form B demand notice does not substitute prior invocation; no default absent prior invocation, petition set aside.
February 16, 2026   Case Laws IBC
Pre-existing contractual disputes can bar CIRP admission if substantial and bona fide; liquidated damages require full adjudication.

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

Transfer pricing comparables had to be tested against functional...

Transfer pricing comparables and working capital adjustment turned on DRP compliance, filter testing, and margin verification.

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Income Tax April 4, 2026 Case Laws AT
Transfer pricing comparables had to be tested against functional similarity, related party transaction limits, segmental data and trading sales filters, and the Assessing Officer was required to follow DRP directions. Peoplelink Unified Communications Pvt. Ltd. was to be excluded because it had already been found functionally different. Zoho Corporation Pvt. Ltd., Quick Heal Technologies Ltd. and RAH Infotech Pvt. Ltd., MSR IT Solution Pvt Ltd. and ESDS Corporation Pvt. Ltd. were sent back for re-examination on the stated filters and annual report data. The operating margin of Compass IT Solutions and Services Pvt Ltd. was also to be verified and corrected if the wrong margin had been applied. Working capital adjustment had to be granted as directed, while consequential interest did not survive on merits.
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Acts Income Tax
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