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    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 inf...
    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 allow...
    October 13, 2026   Case Laws Income Tax
    TNMM functional comparability requires segmental evidence for diversified providers, while receivable interest demands transaction-specific arm's leng...
    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 benchmar...
    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...
    October 13, 2026   Case Laws Income Tax
    Vivad Se Vishwas settlement scope excludes independent reassessment disputes, while unsupported bogus-purchase additions require disclosed transaction...
    October 13, 2026   Case Laws Income Tax
    Functional comparability under TNMM requires transaction-specific FAR analysis before benchmarking business-support services provided to associated en...
    October 13, 2026   Case Laws Income Tax
    Omitted specified-domestic-transaction rules invalidated transfer-pricing adjustments, while derivative losses and exempt-income expenditure limits re...
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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.
October 13, 2026   Case Laws Income Tax
Vivad Se Vishwas settlement scope excludes independent reassessment disputes, while unsupported bogus-purchase additions require disclosed transaction particulars.
October 13, 2026   Case Laws Income Tax
Functional comparability under TNMM requires transaction-specific FAR analysis before benchmarking business-support services provided to associated enterprises.
October 13, 2026   Case Laws Income Tax
Omitted specified-domestic-transaction rules invalidated transfer-pricing adjustments, while derivative losses and exempt-income expenditure limits remained sustainable.

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Income Tax

Functional, asset and risk analysis requires comparables for a...

Functional, asset and risk analysis excludes diversified technology companies from captive software development comparables under cost-plus arrangements.

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Income Tax October 13, 2026 Case Laws AT
Functional, asset and risk analysis requires comparables for a captive software development service provider to reflect its limited-risk, cost-plus operating model. Diversified technology companies with broad service portfolios, substantial brand value and intangibles, significant research and development, goodwill, patents, and different risk profiles are functionally dissimilar. The absence of standalone segmental information further impairs reliable comparison. Infosys Ltd., Wipro Ltd. and LTI Mindtree Ltd. are therefore unsuitable comparables, requiring recomputation of any transfer-pricing adjustment after their exclusion.
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Acts Income Tax
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