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    Royalty and FIS/FTS treatment of database recharge and seconded employee reimbursements under India-USA DTAA held non-taxable
    Article 8 shipping receipts from feeder vessels and slot hire held covered by the DTAA, not separately taxed.
    Arrears of superannuation fund perquisites qualify for salary relief, and Rule 21A applies to the claim.
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    Transfer pricing adjustments remanded for fresh review of intra-group services, sensor assembling method and comparables analysis
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    Comparability filters in TNMM require upfront R&D screening and broadly similar turnover scales for software services.
    Functional comparability in wholesale auto-component trading excludes retail and after-sales comparables, deleting transfer pricing adjustments
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    Transfer pricing comparability: predominantly manufacturing comparables were excluded, and IT support charges were not fixed at nil.
    Substantial compliance in transfer pricing documentation defeats penalty for diamond trade record shortfall where arm's length pricing stood accepted
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      Retrospective substitution of the proviso to section 50(1) means...

      Interest on delayed GST payment applies only to net cash liability after the amended proviso to section 50(1).

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      GSTMay 13, 2026Case LawsHC
      Retrospective substitution of the proviso to section 50(1) means interest on delayed GST payment is chargeable only on the portion discharged through the electronic cash ledger, i.e. the net cash liability. The existing demand therefore had to be tested against the amended legal position, and the authorities were required to reconsider the matter afresh after giving the taxpayer an opportunity of hearing. The petition was disposed of by remitting the issue for fresh decision under the amended proviso.

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      ActsIncome Tax