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    July 14, 2026   Case Laws GST
    Year-wise tax assessments required: composite orders invalid, while writ challenges remain maintainable despite appellate dismissal
    July 14, 2026   Case Laws Income Tax
    Section 56(2)(ix) requires advance negotiations for a capital asset and forfeiture; business land-procurement advances therefore escaped taxation
    July 14, 2026   Case Laws Income Tax
    Mandatory pre-notice inquiry under section 148A: bypassing an approved inquiry invalidates reassessment proceedings and requires fresh action.
    July 14, 2026   Case Laws Income Tax
    Reassessment objections require consideration of later material on funding sources; merits of reopening remain open for fresh decision.
    July 14, 2026   Case Laws Income Tax
    Binding administrative guidance requires consideration in purchase-tax assessments; unexamined tax determinations cannot stand and require fresh recon...
    July 14, 2026   Case Laws Income Tax
    Procedural lapse in Form 56F filing cannot defeat a valid SEZ deduction claim where the report was timely obtained and later uploaded
    July 14, 2026   Case Laws Income Tax
    Sufficient cause and merits-based adjudication guide condonation of delayed appeals challenging section 143(1) processing and exemption denial.
    July 14, 2026   Case Laws Income Tax
    Full and true disclosure governs settlement applications; income cannot be recharacterised under Sections 69B and 115BBE in settlement proceedings
    July 14, 2026   Case Laws Income Tax
    Mandatory DRP directions must shape the final assessment; a post-limitation corrigendum cannot cure the statutory defect.
    July 14, 2026   Case Laws Income Tax
    Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
    July 14, 2026   Case Laws Income Tax
    Adequate enquiry limits section 263 revision; shareholder funding and commercially expedient purchases may avoid tax adjustments
    July 14, 2026   Case Laws Income Tax
    Pecuniary jurisdiction for scrutiny notices is mandatory; notice by the wrong officer can invalidate the resulting assessment.
    July 14, 2026   Case Laws Income Tax
    Open-access medical and educational activities outweigh an isolated religious object clause, supporting charitable registration and donation approval
    July 14, 2026   Case Laws Income Tax
    Non-recourse receivables assignment is a sale, not borrowing; alleged discounting charges are not interest for TDS purposes.
    July 14, 2026   Case Laws Income Tax
    Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
    July 14, 2026   Case Laws Income Tax
    Turnover filters and receivables benchmarking reshape software-services transfer pricing: high-turnover comparables excluded and interest recomputed a...
    July 14, 2026   Case Laws Income Tax
    Consistent depreciation treatment supports computer peripherals, film software libraries and demerged non-compete fees; production costs remain revenu...
    July 14, 2026   Case Laws Income Tax
    Charitable medical relief survives hospital scale, surplus and premium facilities; retrospective registration cancellation and consequential donation ...
    July 14, 2026   Case Laws Income Tax
    Medical relief remains charitable despite premium hospital operations; statutory enquiry focuses on genuine activities and application of income.
    July 14, 2026   Case Laws Income Tax
    Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
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July 14, 2026   Case Laws GST
Year-wise tax assessments required: composite orders invalid, while writ challenges remain maintainable despite appellate dismissal
July 14, 2026   Case Laws Income Tax
Section 56(2)(ix) requires advance negotiations for a capital asset and forfeiture; business land-procurement advances therefore escaped taxation
July 14, 2026   Case Laws Income Tax
Mandatory pre-notice inquiry under section 148A: bypassing an approved inquiry invalidates reassessment proceedings and requires fresh action.
July 14, 2026   Case Laws Income Tax
Reassessment objections require consideration of later material on funding sources; merits of reopening remain open for fresh decision.
July 14, 2026   Case Laws Income Tax
Binding administrative guidance requires consideration in purchase-tax assessments; unexamined tax determinations cannot stand and require fresh reconsideration.
July 14, 2026   Case Laws Income Tax
Procedural lapse in Form 56F filing cannot defeat a valid SEZ deduction claim where the report was timely obtained and later uploaded
July 14, 2026   Case Laws Income Tax
Sufficient cause and merits-based adjudication guide condonation of delayed appeals challenging section 143(1) processing and exemption denial.
July 14, 2026   Case Laws Income Tax
Full and true disclosure governs settlement applications; income cannot be recharacterised under Sections 69B and 115BBE in settlement proceedings
July 14, 2026   Case Laws Income Tax
Mandatory DRP directions must shape the final assessment; a post-limitation corrigendum cannot cure the statutory defect.
July 14, 2026   Case Laws Income Tax
Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration defer taxation.
July 14, 2026   Case Laws Income Tax
Adequate enquiry limits section 263 revision; shareholder funding and commercially expedient purchases may avoid tax adjustments
July 14, 2026   Case Laws Income Tax
Pecuniary jurisdiction for scrutiny notices is mandatory; notice by the wrong officer can invalidate the resulting assessment.
July 14, 2026   Case Laws Income Tax
Open-access medical and educational activities outweigh an isolated religious object clause, supporting charitable registration and donation approval
July 14, 2026   Case Laws Income Tax
Non-recourse receivables assignment is a sale, not borrowing; alleged discounting charges are not interest for TDS purposes.
July 14, 2026   Case Laws Income Tax
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains computation
July 14, 2026   Case Laws Income Tax
Turnover filters and receivables benchmarking reshape software-services transfer pricing: high-turnover comparables excluded and interest recomputed at LIBOR plus 2%
July 14, 2026   Case Laws Income Tax
Consistent depreciation treatment supports computer peripherals, film software libraries and demerged non-compete fees; production costs remain revenue expenditure.
July 14, 2026   Case Laws Income Tax
Charitable medical relief survives hospital scale, surplus and premium facilities; retrospective registration cancellation and consequential donation approval rejection cannot stand
July 14, 2026   Case Laws Income Tax
Medical relief remains charitable despite premium hospital operations; statutory enquiry focuses on genuine activities and application of income.
July 14, 2026   Case Laws Income Tax
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verification

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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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