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    October 13, 2025   Case Laws Income Tax
    Challenge to refusal to admit belated affidavits under Rule 29 dismissed; s.69A afterthought affidavits rejected as prior returns declared amounts
    October 13, 2025   Case Laws Income Tax
    S.69A additions deleted where undated loose paper from third party and audio lacked nexus to assessee
    October 13, 2025   Case Laws Income Tax
    Payments under agreement transferring leasehold development rights held taxable under s.194IC; TDS and s.201(1)/(1A) liability affirmed
    October 13, 2025   Case Laws Income Tax
    Allowed Ground No.2: Company A excluded as non-comparable; include Company B at 2.92% for TP recomputation
    October 13, 2025   Case Laws Income Tax
    Tribunal upholds PCIT's revisionary power under s.263 to correct order prejudicial to revenue on goodwill depreciation
    October 13, 2025   Case Laws Income Tax
    Invocation of section 41(1) raises triable issues; addition set aside pending verification of documents and fresh adjudication
    October 13, 2025   Case Laws Income Tax
    Transfer-pricing adjustments cannot be added to book profits under section 115JB without accounting defect findings
    October 13, 2025   Case Laws Income Tax
    Commission payments to non-resident under exclusive procurement and supply agreement are not "fees for technical services"; section 195 TDS quashed
    October 13, 2025   Case Laws Income Tax
    Appeal allows deletion of downward TP adjustment for GAM charges; TNMM aggregation appropriate as services were inseparable
    October 11, 2025   Case Laws Income Tax
    Penalty under s.271(1)(c) upheld; s.154 rectification not treated as a computational mistake, penalty remains affirmed
    October 11, 2025   Case Laws Income Tax
    s.127 transfer upheld despite ITBA delay; notice u/s 143(2) invalid, s.68 and s.115BBE additions deleted
    October 11, 2025   Case Laws Income Tax
    Ruling: TPO arm's length finding prevents AO ALP adjustments; Rule 8D(2) for section 14A; deductions under 35(2AB) allowed
    October 11, 2025   Case Laws Income Tax
    Ex parte dismissal set aside for noncompliance with s. 250(6); matter remitted for fresh merits adjudication
    October 11, 2025   Case Laws Income Tax
    Appellate order set aside as cryptic; case remanded to AO to examine bank records and decide merits under Section 144
    October 11, 2025   Case Laws Income Tax
    Notional forex loss deletion upheld; residential property interest allowed; Section 14A read with Rule 8D deleted; directors' travel partly disallowed
    October 11, 2025   Case Laws Income Tax
    Appellate order upheld agency treatment; 50% documentation and telex charges treated as proper reimbursements, not international transactions
    October 10, 2025   Notifications Income Tax
    Central Government exempts urban development authority under section 10(46A)(b) for AY 2025-26, subject to conditions -26
    October 10, 2025   Case Laws Income Tax
    Assessment orders confirm logistics/freight receipts are business income, not FTS/FIS under India-USA DTAA and Income-tax Act
    October 10, 2025   Case Laws Income Tax
    APA under s.92CC binds income computation; voluntary ALP reporting preserves s.10AA exemption; adhoc s.14A disallowance unsupported
    October 10, 2025   Case Laws Income Tax
    Transfer pricing adjustments upheld under s.143(3), s.144C(13) and s.92CA(1); Project Office deemed executing arm; s.9/Art.7 attribution affirmed
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All › Income Tax › Income Tax - 2025
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October 13, 2025   Case Laws Income Tax
Challenge to refusal to admit belated affidavits under Rule 29 dismissed; s.69A afterthought affidavits rejected as prior returns declared amounts
October 13, 2025   Case Laws Income Tax
S.69A additions deleted where undated loose paper from third party and audio lacked nexus to assessee
October 13, 2025   Case Laws Income Tax
Payments under agreement transferring leasehold development rights held taxable under s.194IC; TDS and s.201(1)/(1A) liability affirmed
October 13, 2025   Case Laws Income Tax
Allowed Ground No.2: Company A excluded as non-comparable; include Company B at 2.92% for TP recomputation
October 13, 2025   Case Laws Income Tax
Tribunal upholds PCIT's revisionary power under s.263 to correct order prejudicial to revenue on goodwill depreciation
October 13, 2025   Case Laws Income Tax
Invocation of section 41(1) raises triable issues; addition set aside pending verification of documents and fresh adjudication
October 13, 2025   Case Laws Income Tax
Transfer-pricing adjustments cannot be added to book profits under section 115JB without accounting defect findings
October 13, 2025   Case Laws Income Tax
Commission payments to non-resident under exclusive procurement and supply agreement are not "fees for technical services"; section 195 TDS quashed
October 13, 2025   Case Laws Income Tax
Appeal allows deletion of downward TP adjustment for GAM charges; TNMM aggregation appropriate as services were inseparable
October 11, 2025   Case Laws Income Tax
Penalty under s.271(1)(c) upheld; s.154 rectification not treated as a computational mistake, penalty remains affirmed
October 11, 2025   Case Laws Income Tax
s.127 transfer upheld despite ITBA delay; notice u/s 143(2) invalid, s.68 and s.115BBE additions deleted
October 11, 2025   Case Laws Income Tax
Ruling: TPO arm's length finding prevents AO ALP adjustments; Rule 8D(2) for section 14A; deductions under 35(2AB) allowed
October 11, 2025   Case Laws Income Tax
Ex parte dismissal set aside for noncompliance with s. 250(6); matter remitted for fresh merits adjudication
October 11, 2025   Case Laws Income Tax
Appellate order set aside as cryptic; case remanded to AO to examine bank records and decide merits under Section 144
October 11, 2025   Case Laws Income Tax
Notional forex loss deletion upheld; residential property interest allowed; Section 14A read with Rule 8D deleted; directors' travel partly disallowed
October 11, 2025   Case Laws Income Tax
Appellate order upheld agency treatment; 50% documentation and telex charges treated as proper reimbursements, not international transactions
October 10, 2025   Notifications Income Tax
Central Government exempts urban development authority under section 10(46A)(b) for AY 2025-26, subject to conditions -26
October 10, 2025   Case Laws Income Tax
Assessment orders confirm logistics/freight receipts are business income, not FTS/FIS under India-USA DTAA and Income-tax Act
October 10, 2025   Case Laws Income Tax
APA under s.92CC binds income computation; voluntary ALP reporting preserves s.10AA exemption; adhoc s.14A disallowance unsupported
October 10, 2025   Case Laws Income Tax
Transfer pricing adjustments upheld under s.143(3), s.144C(13) and s.92CA(1); Project Office deemed executing arm; s.9/Art.7 attribution affirmed

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