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    April 8, 2026   Case LawsIncome Tax
    Search-related reassessment limitation: HC holds the search assessment year counts in the ten-year block, making the notice time-barred.
    April 8, 2026   Case LawsIncome Tax
    Condonation of delay in filing Form 10B must be decided on the delay explanation alone, not unrelated registration issues.
    April 8, 2026   Case LawsIncome Tax
    Coordinated investigation and incriminating material: transfer upheld, but section 153A notice quashed and reassessment held time barred.
    April 8, 2026   Case LawsIncome Tax
    Section 263 revision fails where the AO made adequate enquiry and adopted one of two plausible views.
    April 8, 2026   Case LawsIncome Tax
    Taxability of contractual receipts follows the accounting method and Form 26AS reflection, ITAT upholds addition.
    April 8, 2026   Case LawsIncome Tax
    Penalty for non-compliance with notice set aside where adjournments were sought and details were later furnished in scrutiny assessment.
    April 8, 2026   Case LawsIncome Tax
    Transfer pricing comparables excluded after remand failure, with arm's length price adjustment recomputed for software services.
    April 8, 2026   Case LawsIncome Tax
    Arm's length pricing of captive power transfers: industrial tariff accepted as the benchmark, and the transfer pricing adjustment was deleted.
    April 8, 2026   Case LawsIncome Tax
    Plausible explanation for offering income and paying tax led ITAT to delete penalty for alleged cash receipts.
    April 8, 2026   Case LawsIncome Tax
    Real income and tax credit principles led to deletion of expense disallowance and verification of self-assessment tax credit.
    April 8, 2026   Case LawsIncome Tax
    Timing mismatch in income recognition requires verification whether receipts were already taxed in an earlier year; matter remitted for fresh examinat...
    April 8, 2026   Case LawsIncome Tax
    Embedded profit in on-money receipts taxed at 10%, with income recognised on sale deed execution, not cash receipt.
    April 8, 2026   Case LawsIncome Tax
    Surcharge on private discretionary trusts: ITAT applies Finance Act slab rates and accepts 15% surcharge instead of 25%.
    April 8, 2026   Case LawsCustoms
    Provisional release conditions: bank guarantee for seized goods held arbitrary, while appeal maintainability was upheld.
    April 8, 2026   Case LawsCustoms
    Ore-to-concentrate conversion defeats CVD exemption where imported manganese has undergone washing, waste removal and sizing.
    April 8, 2026   Case LawsCustoms
    Refund claims filed before final settlement of an exemption dispute are premature and may be rejected.
    April 8, 2026   Case LawsCustoms
    FOB transaction value and export incentives: customs valuation cannot override contractual export benefits or support confiscation without valid proof...
    April 8, 2026   Case LawsCustoms
    Customs Broker due diligence obligations narrowly construed; revocation and penalty set aside for lack of proof of regulatory breach.
    April 8, 2026   Case LawsIBC
    Moratorium protection over leased premises bars lessor from recovering possession while the corporate debtor remains in possession.
    April 8, 2026   Case LawsIBC
    Limitation for CIRP based on DRT recovery certificate was not defeated by absence of a separately stated default date.
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    April 8, 2026   Case Laws Income Tax
    Search-related reassessment limitation: HC holds the search assessment year counts in the ten-year block, making the notice time-barred.
    April 8, 2026   Case Laws Income Tax
    Condonation of delay in filing Form 10B must be decided on the delay explanation alone, not unrelated registration issues.
    April 8, 2026   Case Laws Income Tax
    Coordinated investigation and incriminating material: transfer upheld, but section 153A notice quashed and reassessment held time barred.
    April 8, 2026   Case Laws Income Tax
    Section 263 revision fails where the AO made adequate enquiry and adopted one of two plausible views.
    April 8, 2026   Case Laws Income Tax
    Taxability of contractual receipts follows the accounting method and Form 26AS reflection, ITAT upholds addition.
    April 8, 2026   Case Laws Income Tax
    Penalty for non-compliance with notice set aside where adjournments were sought and details were later furnished in scrutiny assessment.
    April 8, 2026   Case Laws Income Tax
    Transfer pricing comparables excluded after remand failure, with arm's length price adjustment recomputed for software services.
    April 8, 2026   Case Laws Income Tax
    Arm's length pricing of captive power transfers: industrial tariff accepted as the benchmark, and the transfer pricing adjustment was deleted.
    April 8, 2026   Case Laws Income Tax
    Plausible explanation for offering income and paying tax led ITAT to delete penalty for alleged cash receipts.
    April 8, 2026   Case Laws Income Tax
    Real income and tax credit principles led to deletion of expense disallowance and verification of self-assessment tax credit.
    April 8, 2026   Case Laws Income Tax
    Timing mismatch in income recognition requires verification whether receipts were already taxed in an earlier year; matter remitted for fresh examination.
    April 8, 2026   Case Laws Income Tax
    Embedded profit in on-money receipts taxed at 10%, with income recognised on sale deed execution, not cash receipt.
    April 8, 2026   Case Laws Income Tax
    Surcharge on private discretionary trusts: ITAT applies Finance Act slab rates and accepts 15% surcharge instead of 25%.
    April 8, 2026   Case Laws Customs
    Provisional release conditions: bank guarantee for seized goods held arbitrary, while appeal maintainability was upheld.
    April 8, 2026   Case Laws Customs
    Ore-to-concentrate conversion defeats CVD exemption where imported manganese has undergone washing, waste removal and sizing.
    April 8, 2026   Case Laws Customs
    Refund claims filed before final settlement of an exemption dispute are premature and may be rejected.
    April 8, 2026   Case Laws Customs
    FOB transaction value and export incentives: customs valuation cannot override contractual export benefits or support confiscation without valid proof.
    April 8, 2026   Case Laws Customs
    Customs Broker due diligence obligations narrowly construed; revocation and penalty set aside for lack of proof of regulatory breach.
    April 8, 2026   Case Laws IBC
    Moratorium protection over leased premises bars lessor from recovering possession while the corporate debtor remains in possession.
    April 8, 2026   Case Laws IBC
    Limitation for CIRP based on DRT recovery certificate was not defeated by absence of a separately stated default date.

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      Income Tax

      In transfer pricing benchmarking for captive software support...

      Transfer pricing comparables excluded for captive software and ITES services due to functional dissimilarity and intangibles.

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      Income TaxMay 12, 2026Case LawsAT
      In transfer pricing benchmarking for captive software support and ITES services, companies with significant intangibles, brand value, patents, R&D functions, product-based operations, diversified activities or extraordinary events were found functionally dissimilar and excluded as comparables. Infosys Technologies Ltd., Wipro Ltd., Kals Information Systems Ltd., Celestial Labs Ltd., Avani Cimcon Technologies Ltd., E-Zest Solutions Ltd., Mold-Tek Technologies Ltd., Accentia Technologies Ltd., Eclerx Services Ltd., Infosys BPO Ltd., HCL Comnet System & Services Ltd., Acropetal Technologies Ltd., Genesys International Corporation Ltd. and Datamatics Financial Services Ltd. were excluded. Tata Elxsi Ltd. and Persistent Systems Private Ltd. were remitted for fresh consideration because no specific examination had been made. Coral Hub Ltd. remained included as the objection was not pressed.
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      ActsIncome Tax
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