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October 13, 2026   Circulars DGFT
Restricted silver imports may clear under a valid import authorisation without additional status or exchange-routing requirements unless expressly imposed.
October 13, 2026   Circulars FEMA
Foreign Exchange Risk Reserve imposes daily cash collateral and reporting duties on qualifying INR derivative hedging contracts.
October 13, 2026   Case Laws GST
Cash seizure under CGST search powers requires clear statutory authority, objective reasons, and evidentiary relevance despite appellate remedies.
October 13, 2026   Case Laws GST
Show cause notice limits prevent unproposed penalties, requiring fresh adjudication when orders exceed the notified demand.
October 13, 2026   Case Laws GST
Statutory stay of GST recovery bars adjustment of eligible refunds against disputed demands after appellate pre-deposit.
October 13, 2026   Case Laws GST
GST audit finalisation requires consideration of objections; notices based on non-final observations cannot validly stand.
October 13, 2026   Case Laws GST
Inverted duty refunds remain available where higher-taxed inputs cause credit accumulation, despite matching rates for a principal input.
October 13, 2026   Case Laws GST
Departmental appeals after GST registration restoration become infructuous when the Department has implemented the appellate orders.
October 13, 2026   Case Laws GST
Statutory condonation limits restrict delayed GST cancellation appeals, but implemented registration restorations can make departmental challenges infructuous.
October 13, 2026   Case Laws Income Tax
Income-tax information remains protected personal data; maintenance claims do not establish larger public interest for RTI disclosure.
October 13, 2026   Case Laws Income Tax
Notional interest on tenancy deposits cannot be taxed without a right to receive interest or suppressed rent.
October 13, 2026   Case Laws Income Tax
Head Office cost allocation requires prescribed transfer-pricing methods; treaty ceilings bar surcharge and cess, while duplicate taxation is excluded.
October 13, 2026   Case Laws Income Tax
Post-detection income surrender does not shield bogus expenditure claims from penalties for misreporting and under-reported income.
October 13, 2026   Case Laws Income Tax
Residential reinvestment relief covers pre-transfer flats funded by housing loans, while unsupported cash deposits remain taxable.
October 13, 2026   Case Laws Income Tax
Transfer-pricing comparability adjustments require quantified evidence, while regulatory borrowing ceilings do not replace arm's-length benchmarking.
October 13, 2026   Case Laws Income Tax
Cost-to-cost reimbursement of seconded employees is not service consideration; transfer-pricing markup was deleted and amalgamation amortisation allowed.
October 13, 2026   Case Laws Income Tax
TNMM functional comparability requires segmental evidence for diversified providers, while receivable interest demands transaction-specific arm's length benchmarking.
October 13, 2026   Case Laws Income Tax
Aggregation of linked transfer-pricing transactions validated netted know-how fees, while unsupported director incentive disallowance could not stand.
October 13, 2026   Case Laws Income Tax
Crystallisation of liability supports prior-period expense deduction, while functionally distinct divisions require separate transfer-pricing benchmarking.
October 13, 2026   Case Laws Income Tax
Manufacturing scrap deductions and exempt-income disallowance safeguards upheld, while royalty benchmarking proceeds for fresh transfer-pricing review.

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Home › Highlights › Income Tax › 2026 › October, 2026 › This
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Income Tax

Section 153C limitation requires the six-year look-back period...

Section 153C limitation invalidates a notice where the relevant assessment year falls outside the statutory look-back period.

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Income Tax October 5, 2026 Case Laws HC
Section 153C limitation requires the six-year look-back period to be calculated from the assessment year immediately preceding the year in which the satisfaction note is recorded. Where the satisfaction note was recorded in AY 2023-24, the period extended only to AY 2017-18; AY 2016-17 lay outside it. The notice for AY 2016-17 was therefore time-barred and quashed, and the writ petition succeeded.
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