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    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...
    October 13, 2026   Case Laws Income Tax
    Advance pricing agreement methodology can guide benchmarking for non-covered years when functions, assets, risks and activities remain materially unch...
    October 13, 2026   Case Laws Income Tax
    MAT credit succession on amalgamation allows a transferee to claim available unutilised credit under a sanctioned scheme, subject to verification.
    October 13, 2026   Case Laws Income Tax
    Advertisement expenditure as brand-promotion service requires proof of an arrangement; adjustment deleted and other tax computations remanded.
    October 13, 2026   Case Laws Income Tax
    Tax-audit exemption for substantially State-funded educational universities prevents audit-failure penalties where income qualifies for statutory exem...
    October 13, 2026   Case Laws Income Tax
    Notional interest on delayed trade receivables may be deleted when financial records verify the taxpayer is completely debt-free.
    October 13, 2026   Case Laws Income Tax
    Functional, asset and risk analysis excludes diversified technology companies from captive software development comparables under cost-plus arrangemen...
    October 13, 2026   Case Laws Income Tax
    Retracted search surrenders without corroboration cannot sustain undisclosed-income additions; no section 14A disallowance arises without exempt incom...
    October 13, 2026   Case Laws Income Tax
    Charitable trust registration cancellation requires proof of non-genuine activities, while year-specific irregular receipts remain assessment matters.
    October 13, 2026   Case Laws Benami Property
    Benami cash routing through third-party bank accounts permits attachment of remaining balances and traceable converted funds.
    October 13, 2026   Case Laws Customs
    Rectification jurisdiction excludes merits review where objections challenge concluded penalty findings rather than patent errors on the record.
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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.
October 13, 2026   Case Laws Income Tax
Advance pricing agreement methodology can guide benchmarking for non-covered years when functions, assets, risks and activities remain materially unchanged.
October 13, 2026   Case Laws Income Tax
MAT credit succession on amalgamation allows a transferee to claim available unutilised credit under a sanctioned scheme, subject to verification.
October 13, 2026   Case Laws Income Tax
Advertisement expenditure as brand-promotion service requires proof of an arrangement; adjustment deleted and other tax computations remanded.
October 13, 2026   Case Laws Income Tax
Tax-audit exemption for substantially State-funded educational universities prevents audit-failure penalties where income qualifies for statutory exemption.
October 13, 2026   Case Laws Income Tax
Notional interest on delayed trade receivables may be deleted when financial records verify the taxpayer is completely debt-free.
October 13, 2026   Case Laws Income Tax
Functional, asset and risk analysis excludes diversified technology companies from captive software development comparables under cost-plus arrangements.
October 13, 2026   Case Laws Income Tax
Retracted search surrenders without corroboration cannot sustain undisclosed-income additions; no section 14A disallowance arises without exempt income.
October 13, 2026   Case Laws Income Tax
Charitable trust registration cancellation requires proof of non-genuine activities, while year-specific irregular receipts remain assessment matters.
October 13, 2026   Case Laws Benami Property
Benami cash routing through third-party bank accounts permits attachment of remaining balances and traceable converted funds.
October 13, 2026   Case Laws Customs
Rectification jurisdiction excludes merits review where objections challenge concluded penalty findings rather than patent errors on the record.

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

Computer software licence payments fall within the royalty...

Prospective software royalty clarification prevents tax-deduction disallowance for pre-effective-date licence renewals, while payable includes paid sums.

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Income Tax October 14, 2026 Case Laws HC
Computer software licence payments fall within the royalty clarification only prospectively from 1 April 2012. Tax deducted on payments to foreign suppliers does not, by itself, establish taxability of comparable payments to domestic suppliers, which require independent examination; consequently, the stated software licence renewals attracted no tax-deduction disallowance. For tax-deduction disallowance, "payable" includes amounts already paid. One-time non-refundable membership fees are recognised over the membership period, supporting apportioned recognition rather than immediate treatment in full.
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