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    September 19, 2026   Case Laws GST
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    GST registration cancellation beyond show-cause notice was quashed, with fresh proceedings permitted after a hearing.
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    Section 47(xiii) succession remains exempt despite pre-conversion capital withdrawals, while section 153A fails without incriminating material.
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September 19, 2026   Case Laws GST
GST reimbursement for post-GST works contracts requires assessment under the notification's applicable provision, not the pre-GST clause.
September 19, 2026   Case Laws GST
GST registration cancellation beyond show-cause notice was quashed, with fresh proceedings permitted after a hearing.
September 19, 2026   Case Laws GST
Special GST law bars general criminal prosecution where alleged tax defaults are already addressed under the CGST framework.
September 19, 2026   Case Laws GST
Alternative statutory remedy requires appellate exhaustion before direct writ challenges to GST assessment and rectification orders proceed.
September 19, 2026   Case Laws GST
Weekly-market fee collection rights leased by Panchayats remain public-authority functions and fall outside GST when linked to markets and fairs.
September 19, 2026   Case Laws GST
Bovine semen sorting is taxable as a scientific and technical service, not exempt animal husbandry support.
September 19, 2026   Case Laws GST
Input tax credit on land-survey services is unavailable for land surrendered to fulfil afforestation obligations.
September 19, 2026   Case Laws Income Tax
Specific condonation circular governs delayed co-operative society returns claiming Section 80P deductions amid genuine hardship.
September 19, 2026   Case Laws Income Tax
Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within statutory limitation.
September 19, 2026   Case Laws Income Tax
Section 47(xiii) succession remains exempt despite pre-conversion capital withdrawals, while section 153A fails without incriminating material.
September 19, 2026   Case Laws Income Tax
Venture capital fund exemption survives separate schemes, trustees' fiduciary holdings, and uncancelled regulatory registration for tax purposes.
September 19, 2026   Case Laws Income Tax
Section 270A penalties cannot rest on disclosed APA adjustments, precedent-supported CSR claims, or later retrospective education-cess amendments.
September 19, 2026   Case Laws Income Tax
Functional characterisation of spare replacement services supports TNMM over RPM where customer and resale-price control are absent.
September 19, 2026   Case Laws Income Tax
Modified returns after business reorganisation must be assessed within pending proceedings, barring parallel scrutiny and consequential transfer pricing action.
September 19, 2026   Case Laws Income Tax
Information suggesting income escapement cannot support reassessment where it merely seeks verification through a roving inquiry.
September 19, 2026   Case Laws Income Tax
Valid reassessment information excludes demerger receipts already taxed by resulting company, defeating extended limitation for reassessment.
September 19, 2026   Case Laws Income Tax
Service of reassessment notices to inactive contact details requires renewed response opportunity before consequential proceedings can stand.
September 19, 2026   Case Laws Income Tax
Alternative concession on agricultural-loss disallowance barred a subsequent challenge to the accepted disallowance in appellate proceedings.
September 19, 2026   Case Laws Income Tax
Reassessment safeguards require independent inquiry, compliance with approved insolvency plans, third-party disclosure, and statutory limitation.
September 19, 2026   Case Laws Income Tax
Functional and financial comparability excludes companies lacking verifiable disclosures, similar business profiles, or qualifying employee costs.

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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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