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Sections 92A(1) and 92A(2) require a harmonious reading: the statutory circumstances in section 92A(2), including business dependence under section 92A(2)(g), do not independently establish an associated-enterprise relationship without participation in management, control or capital under section 92A(1). Commercial dependence or distribution exclusivity alone is insufficient absent evidence of ownership, voting rights, managerial participation or financial control. For internal CUP analysis, contractual differences do not disqualify an uncontrolled transaction unless they materially affect the royalty rate and cannot be eliminated through reasonably accurate, objectively verifiable adjustments. Royalty benchmarking was remanded to examine those differences and adjustments; if CUP is unreliable, the most appropriate method must be independently selected.

Sale proceeds of Renewable Energy Certificates received by renewable-energy power generators are treated as capital receipts because the certificates incentivise environmental benefits of renewable generation rather than arise from producing or selling goods or rendering services. They therefore do not constitute business income or profits derived from an eligible power-generation undertaking for deduction purposes. As capital receipts, the proceeds are also excluded from book profit computed for minimum alternate tax purposes under section 115JB. The Revenue's challenge to deletion of the related disallowance and to exclusion from book profit was rejected.

Prospective operation of a customs exemption amendment prevents its use against imports where the Bill of Lading predates the amendment's effective date and no retrospective effect is expressly provided. A request for provisional release of used digital multifunction print, copying and scanning machines must therefore be considered under Section 110A without relying on the later amendment. Release may be granted subject to lawful conditions and remains subject to adjudication. The applicable duty rate is to be determined under Section 15 of the Customs Act, 1962.

Appellate restraint governs interference with disciplinary penalties under the Customs Broker Licensing Regulations. The original authority must assess the evidence and select an appropriate sanction; an appellate forum cannot replace that choice merely because another penalty is possible, absent arbitrariness, perversity or legal infirmity. Licence revocation, which can end the broker's business, is not automatic for every regulatory breach and must remain proportionate to the proved misconduct. Suspicion, however strong, cannot substitute legal proof. As no defect was established in the Commissioner's decision to impose a monetary penalty instead of revocation, the departmental challenge and request for remand were rejected.

Pre-institution mediation under Section 12A is mandatory for commercial suits that do not contemplate urgent interim relief. Whether the exception applies must be assessed from the plaintiff's standpoint, considering the suit's nature, cause of action and pleaded need for immediate protection; an unfounded urgency plea cannot bypass mediation. Urgent relief was genuinely contemplated where the suit sought investor recovery, earlier disclosures were inadequate, and ad-interim disclosure and asset-protection measures had already been granted despite existing regulatory restraints. The subsequent delay objection failed because investor claims had to be received before institution. Pre-institution mediation was therefore not a condition precedent, and rejection of the plaint under Order VII Rule 11 was unwarranted.

Registrar's statutory power to frame service rules includes the power to amend, vary or rescind them. Deletion of a service-rule bar preventing technical employees from promotion to non-technical posts remains valid where ordered by the Registrar; a communication issued by an Additional Registrar may convey that decision, and its nomenclature as a circular does not displace the underlying statutory authority. A statutory requirement to lay amended rules before the Legislative Assembly is directory, despite use of "shall", where no consequence follows from non-laying. Non-compliance therefore does not invalidate the amendment or a promotion made under it.

PMLA / Black Money
Dated:- 24-8-2026
PTI
Prior prosecution sanction is asserted to be a jurisdictional precondition for money-laundering proceedings against a public servant for acts connected with official duty. A former police officer challenges cognizance and process for want of sanction under the criminal procedure framework and the Maharashtra Police Act, relying on sanctions subsequently granted for co-accused public servants. The allegations concern collection of funds through the officer and their alleged laundering through an educational trust.

FEMA / RBI
Dated:- 24-8-2026
PTI
Rupee exchange-rate movement against the US dollar reflected a marginal appreciation, supported by foreign fund inflows into domestic equities. Trading remained within a narrow range amid pressures from higher crude oil prices, continuing importer demand, and geopolitical concerns. Market conditions also included a stronger dollar index, lower Brent crude futures, domestic equity declines, and net foreign institutional investment. Elevated oil prices and geopolitical uncertainty indicated a slight negative bias, while possible US dollar weakness could support the rupee.

Customs & Trade
Dated:- 24-8-2026
PTI
Canada-United States trade relations involve escalating tariffs and contemplated reciprocal restrictions affecting goods, automotive production, electricity exports and critical-mineral supplies. Potential Canadian countermeasures include limiting or increasing the price of Ontario electricity exports and restricting supplies of critical minerals, with oil and potash also identified as possible leverage. The automotive sector faces particular exposure because Ontario production and supply chains are integrated with United States manufacturing. Negotiations also raised concern over limits on Canada's ability to conclude trade agreements with other countries without United States approval.

Grant of a contractual put option allows specified holders of economic-rights equity shares to require another shareholder group to purchase their shares on stipulated terms, without separate consideration payable to the company. GST taxability depends on whether this right to sell is a supply of services. The transaction is characterised as non-taxable because it concerns securities, which are excluded from the definitions of both goods and services.

Corp. Laws / SEBI / IBC
Dated:- 24-8-2026
PTI
Mandatory Biometric Update camps have been launched in schools across Tamulpur district, Assam, for eligible students aged 5 to 17 years to update Aadhaar biometrics. Aadhaar biometrics require updating on attaining five years of age and again on attaining fifteen years. Timely updating supports continued Aadhaar authentication and helps avoid difficulties in accessing services where authentication is applicable, including school admissions, entrance-examination registration, scholarships and Direct Benefit Transfer schemes.

Customs & Trade
Dated:- 24-8-2026
PTI
Electricity tariff increase in Jammu and Kashmir has been opposed as imposing an unjustified and unaffordable financial burden on domestic consumers amid rising household costs. Immediate review and withdrawal of the increase are sought, together with measures to reduce electricity costs for domestic consumers, particularly economically weaker sections, and ensure affordable, reliable power supply.

Customs & Trade
Dated:- 24-8-2026
PTI
Wheat and wheat-product exports are liberalised with immediate effect by revising their export policy from prohibited to free. The change covers wheat, wheat flour, maida, semolina and wholemeal atta, replacing the earlier export-ban framework and simplifying exports previously permitted through licences. The measure aims to support farmers amid depressed domestic prices, while adequate domestic availability and buffer stocks are expected to meet demand and moderate consumer prices.

Corp. Laws / SEBI / IBC
Dated:- 24-8-2026
PTI
Food safety enforcement measures resulted in suspension of food licences or registrations where establishments failed hygiene, food handling, storage, refrigeration, sanitation and licensing requirements. Deficiencies included unsafe temperature control, unclean refrigeration equipment, improper food storage and thawing, inadequate sanitisation, deteriorated or expired materials, deficient oil-quality checks, artificial colouring, pest infestation, cross-contamination risks and inadequate drainage. One outlet was also found to be operating under the name of an establishment without a valid food licence, resulting in suspension of its registration certificate.

FEMA / RBI
Dated:- 24-8-2026
PTI
Appointments to the Reserve Bank of India's Central Board expand its part-time, non-official director membership. Syed Akbaruddin, Annie George Mathew and Janmejaya Kumar Sinha have been appointed for four years from 24 August 2026, or until further orders, whichever occurs earlier. The Central Board also includes the Governor, deputy governors, the economic affairs secretary and the financial services secretary.

2025 (10) TMI 1457
Case Laws Indian Laws
Limitation for externment appeals bars relief where substantial delay lacks a bona fide explanation and statutory condonation is unavailable.
Statutory appeals against externment orders must be filed within the prescribed limitation period. A substantial delay, unsupported by a bona fide explanation before either the appellate authority or the High Court, does not justify interference with dismissal as time-barred. Although the High Court may condone delay in an appropriate case, that power depends on a genuine explanation and cannot be used to bypass a statutory limitation regime that does not permit condonation. The time-barred dismissal of the statutory appeal therefore remained undisturbed.

2024 (12) TMI 1793
Case Laws Income Tax
Foreign investment evidence defeats unexplained cash-credit additions, while delayed employee provident fund contributions remain non-deductible.
Foreign investment received as share capital, share premium and compulsorily convertible debentures is not taxable as unexplained cash credit where investment agreements, tax-residency certificates, inward-remittance records, audited financial statements and cross-border verification establish the investors' identity, creditworthiness and transaction genuineness, and remain unrebutted. Interest on debentures is allowable where the underlying investment or loan stands accepted and no distinct basis supports disallowance. Employees' provident fund contributions paid after the prescribed statutory due date are not deductible, consistently with Checkmate Services Pvt. Ltd.

2025 (1) TMI 1851
Case Laws Income Tax
Transfer-pricing study review requires adequate examination before arm's length price determination, requiring de novo adjudication after fresh consideration.
Transfer-pricing adjustments require a fair opportunity for proper examination and verification of the taxpayer's transfer-pricing study report before determining the arm's length price. Where the report is furnished shortly before the transfer-pricing order and insufficient time is available for review, fairness requires fresh consideration. The assessment, transfer-pricing and Dispute Resolution Panel orders were set aside, with the matter restored for de novo transfer-pricing adjudication after examination of the study report.

2025 (3) TMI 2309
Case Laws Income Tax
Defective penalty notices lacking a specific charge invalidate concealment or inaccurate-particulars penalties and require their deletion.
Penalty notices for concealment of income or furnishing inaccurate particulars must specify the exact charge by striking out the inapplicable statutory limb. Retaining both alternatives without clarification fails to give the taxpayer clear notice of the allegation and impairs an effective defence. Such ambiguity vitiates initiation of penalty proceedings. The defect applied to both assessment years, rendering the penalty notices invalid and the penalties unsustainable; the penalties were deleted.

2025 (3) TMI 2310
Case Laws Income Tax
Revisionary jurisdiction fails where cash deposits were examined in assessment and revision rests on an incorrect factual premise.
Revisionary jurisdiction cannot be exercised on an incorrect factual premise where the assessment record shows that the Assessing Officer examined and accepted the explanation for cash deposits. The revision relied on a deposit figure inconsistent with departmental bank details, while the assessment had already obtained information, considered the taxpayer's response and made no addition. The alleged inadequate enquiry was therefore factually unsustainable, rendering the revision order without valid jurisdiction and liable to be quashed.

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