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    Condonation of delay for Form 10-IC limited by CBDT circular language and three-year filing period
    Retrospective royalty amendments cannot justify TDS on IPLC payments where the non-resident had no permanent establishment.
    Deferred revenue recognition for time-share fees upheld where contractual obligations extended over the membership period.
    Reopening on search material requires a live nexus with the assessee; vague and disconnected documents cannot justify Section 148 action.
    Reassessment on investigation inputs upheld, but share sale proceeds could not be taxed as unexplained cash credits
    Long-term capital asset treatment upheld where possession and full payment occurred before later registration, with indexation allowed.
    Concessionaire rights under a DBFOT highway deal qualify as depreciable intangible assets, with depreciation allowed on written down value.
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    Transfer pricing limitation and DTAA relief: time-bar finding reversed, merits remanded, fresh treaty claim not admitted.
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    Aggregated TNMM and CSR donation deduction principles shape transfer pricing relief and section 80G allowance
    Transfer pricing turnover filter upheld, while inclusion of comparables was remanded for fresh factual verification.
    Transfer pricing comparables, working capital and receivables interest recalibrated; section 234A relief and 234C recomputation granted.
    Prospective royalty amendment ruling: IPLC bandwidth payments were not taxable, so no TDS disallowance could stand.
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    Deferred revenue recognition upheld for long-term membership fees matched against continuing facilities obligations.
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    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.
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Acts Income Tax