Just a moment...

Top
Help
×

By creating an account you can:

Logo TaxTMI
Call Us / Help / Feedback

Contact Us At :

E-mail: [email protected]

Call / WhatsApp at: +91 99117 96707

For more information, Check Contact Us

FAQs :

To know Frequently Asked Questions, Check FAQs

Most Asked Video Tutorials :

For more tutorials, Check Video Tutorials

Submit Feedback/Suggestion :

Email :
Please provide your email address so we can follow up on your feedback.
Category :
Description :
Min 15 characters0/2000
Make Most of Text Search
  1. Checkout this video tutorial: How to search effectively on TaxTMI.
  2. Put words in double quotes for exact word search, eg: "income tax"
  3. Avoid noise words such as : 'and, of, the, a'
  4. Sort by Relevance to get the most relevant document.
  5. Press Enter to add multiple terms/multiple phrases, and then click on Search to Search.
  6. Text Search
  7. The system will try to fetch results that contains ALL your words.
  8. Once you add keywords, you'll see a new 'Search In' filter that makes your results even more precise.
  9. Text Search
Add to...
You have not created any category. Kindly create one to bookmark this item!
Create New Category
Hide
Title :
Description :
❮❮ Hide
Default View
Expand ❯❯
Close ✕
🔎 Highlights - Adv. Search
TEXT SEARCH:

Press 'Enter' to add multiple search terms. Rules for Better Search

Search In:
Main Text + AI Text
  • Main Text
  • Main Text + AI Text
  • AI Text
Law:
---- All Laws----
  • ---- All Laws----
  • Income Tax
  • Direct Taxes
  • Benami Property
  • Central GST Laws
  • SGST - State GST Laws
  • Customs
  • FTP - Foreign Trade Policy
  • SEZ - Special Economic Zone
  • FEMA - Foreign Exchange Management
  • Companies Law
  • SEBI - Securities & Exchange Board of India
  • IBC - Insolvency and Bankruptcy
  • Law of Competition
  • PMLA - Money-Laundering
  • Indian Laws
  • Bill / Finance Bills
  • Wealth Tax
  • Service Tax
  • Central Excise
  • VAT / Sales Tax
Month:
---- All Months ----
  • ---- All Months ----
  • January
  • February
  • March
  • April
  • May
  • June
  • July
  • August
  • September
  • October
  • November
  • December
Year:
---- All Years ----
  • ---- All Years ----
  • 2026
  • 2025
  • 2024
  • 2023
  • 2022
  • 2021
  • 2020
  • 2019
  • 2018
  • 2017
  • 2016
  • 2015
  • 2014
  • 2013
  • 2012
  • 2011
Sort By: ?
In Sort By 'Default', exact matches for text search are shown at the top, followed by the remaining results in their regular order.
RelevanceDefaultDate
    Approved resolution plan extinguishes pre-CIRP tax dues, preventing adjustment of income-tax refunds against barred claims.
    Cash sale consideration in registered property transfers held outside section 269SS, and penalty failed for lack of recorded satisfaction.
    Section 153C search assessments and electronic evidence fail without Section 65B compliance or corroboration.
    Joint transferee TDS threshold under immovable property purchases must be tested on each purchaser's share, not the total deed value.
    Transfer pricing operating margin: SEIS reversal, foreign exchange gains and working capital adjustment shape TNMM comparability
    Transfer pricing comparability under TNMM refined: functional filters, aggregate RPT testing, and working capital adjustments controlled the outcome.
    TNMM and transfer pricing adjustments: receivables deleted, ECB interest upheld, leasehold amortisation allowed, royalty remanded
    Transfer pricing under External TNMM prevails where internal comparables and segment re-casting lack factual support.
    Transfer pricing on overdue receivables and CSR-linked 80G deduction were reshaped by the Tribunal's recomputation directions.
    Deemed valuation for solar power composite supply applies despite separate invoices; differential 18% levy on entire turnover set aside.
    GST proceedings against a non-existent amalgamating company are void ab initio; merger intimation defeats jurisdiction under Section 87.
    Reasoned GST cancellation orders are mandatory; a non-speaking cancellation order was set aside despite the taxpayer's delay.
    Condonation of delay in GST appeal allowed where circumstances beyond control justified hearing the matter on merits.
    Provisional attachment cannot be reissued on the same facts after expiry, and it cannot serve as a post-assessment recovery device.
    GST summons during inquiry upheld as proper officer's statutory power cannot be stalled by writ intervention.
    Statutory remedy and ongoing investigation barred writ relief against GST registration cancellation and blocked input tax credit.
    Non-consideration of material evidence invalidates denial of transitional credit and requires fresh speaking order.
    Non-obstante clause in GST ITC rules overrides the filing-time bar, requiring reconsideration of a delayed claim.
    Vague GST cancellation notice and undisclosed retrospective effect violated natural justice, leading to quashing of the order.
    Anti-profiteering on additional ITC: Tribunal upheld refund of unpassed benefit, GST component, interest, and penalty exposure.
❯❯
MaximizeMaximizeMaximize
0 / 200
Expand Note
Add to Folder

No Folders have been created

    +

    Are you sure you want to delete "My most important" ?

    NOTE:

    Highlights
    Showing Results for :
    Reset Filters
    Results Found:
    Show All SummariesHide All Summaries

    Highlights

    Back

    All Highlights

    Showing Results for :
    Reset Filters
      No Records Found

      Highlights

      Back

      All Highlights

      whatsappJoin Channel
      Showing Results for : Reset Filters

      In a transfer pricing dispute involving software development...

      Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit verification directed.

      Contents
      Summary
      Note

      Note

      -

      Bookmark

      Print

      Print

      Income TaxApril 29, 2026Case LawsAT
      In a transfer pricing dispute involving software development services, the ITAT held that the persistent loss filter applied only where a company incurred losses in all three relevant years, so DCIS Dot Com Solutions India Pvt. Ltd. and Rheal Software Pvt. Ltd. were to be included as comparables. It further held that Mind Tree Limited and Nihilent Limited were functionally dissimilar, lacked usable segmental information for software development services, and were to be excluded as comparables. Foreign exchange gain arising from realization of service receivables was held to be operating income for PLI computation. The claim for risk adjustment was restored for fresh consideration, and credit for self-assessment tax and TCS was directed to be granted after verification.

      Topics

      ActsIncome Tax