Transfer-pricing comparability requires valid economic criteria, including uniform application of a ten-times turnover filter; prior inclusion in a taxpayer's study does not prevent a later comparability challenge. Functional comparability requires verification of functions, assets and risks, including relevant filters for disputed companies. Foreign-currency receivables should be benchmarked to the relevant foreign-currency market rate, with LIBOR plus 200 basis points applied instead of domestic rupee rates. Provisions for bad and doubtful debts are not operating costs because they do not represent actual expenditure. Negative working-capital adjustments require examination of working-capital risk and an adequate opportunity to be heard.

Minimum Alternate Tax under section 115JB is inapplicable to a corresponding new bank constituted under the Banking Companies (Acquisition and Transfer of Undertakings) Act, 1970. The book-profit computation provision applies only where the second proviso to section 129(1) of the Companies Act, 2013 applies. Such a bank is neither formed nor registered under the Companies Act and is not a banking company for that provision. Its deemed status as an Indian company for Income-tax Act purposes cannot extend to Companies Act status; therefore, book-profit tax cannot be levied.

Reassessment notice - minimum opportunity under section 148A(b) - Jurisdictional defect - curability under sections 292B and 292BB Validity of reassessment initiated on a notice under section 148A(b) allowing less than the statutory minimum time to respond, and applicability of sections 292B and 292BB - HELD THAT: - Section 148A(b) mandates that the assessee be afforded not less than seven days to respond to the show-cause notice preceding issuance of a notice under section 148. As the notice... ... ...

Deduction of interest on investments with co-operative society - Deduction of interest on surplus deposits with co-operative and commercial banks - Deduction of expenditure against income from other sources Deduction of interest on investments with co-operative society - Deduction under section 80P(2)(d) of interest earned on fixed and savings deposits maintained with another registered co-operative society. - HELD THAT: - Interest or dividend earned by a co-operative society from investments... ... ...

Estimation of brokerage commission on cash finance transactions Assessment of cash receipts and payments recorded in seized material relating to finance-brokering activity - HELD THAT: - The seized document showed cash receipts and payments, and established that the assessee acted as a broker for arranging finance against commission. Since, in the assessee's own cases for earlier years, commission income had been estimated at 3% of total receipts and the Revenue's appeals had been ... ... ...

Faceless reassessment notices issued by jurisdictional AO - Competent approval for reassessment notice issued beyond three years Faceless reassessment notices issued by jurisdictional Assessing Officer - Validity of reassessment notices issued by the jurisdictional Assessing Officer, rather than the faceless Assessing Officer, under the National Faceless Assessment Scheme - HELD THAT: - The reassessment notices were issued by the jurisdictional Assessing Officer and not through the faceless p... ... ...

Unexplained money u/s 69A - proof of ownership and receipt - Uncorroborated WhatsApp chats as evidence of cash receipt Sustainability of addition as unexplained money under section 69A on the alleged receipt of sale consideration from a Dubai property, founded on WhatsApp chats - HELD THAT: - The Tribunal held that the WhatsApp extracts, without independent corroboration, could not by themselves establish the assessee's ownership of, or receipt of, the alleged sale consideration. No cash ... ... ...

Rejection of the application to condone a 13-day delay filling ITR - Genuine hardship u/s 119(2)(b) - Condonation of delay in filing return for deduction claim u/s 80IBA, where the delay was attributed to COVID-19-related restrictions HELD THAT: - The Circular relied upon was inapplicable, as it dealt with belated refund claims and claims for carry forward of loss. The power under section 119(2)(b) required consideration of the grounds explaining the delay; the pandemic-related restrictions p... ... ...

Arms-licensing discretion requires a police report before grant unless the statutory proviso permits action without it after the prescribed period; where no period is prescribed, the authority must allow reasonable time in the circumstances. Prosecution sanction for public servants requires visible, independent application of mind, identifying the material considered and the basis for prima facie satisfaction; generic references to case-diary material are insufficient. The right to speedy trial extends to investigation, including further investigation. Exceptional, unexplained delay requires continuing judicial oversight and recorded justification, and may support relief under applicable inherent-jurisdiction provisions. Invalid sanction and unjustified prolonged investigation make continuation of criminal proceedings untenable.

Section 68 addition for cash deposits in demonetised currency was considered unsustainable where deposits aligned with the business's substantial turnover, wholesale pharmaceutical operations, geographical spread, and collection practices. The maintained cash book had been furnished and no defect was identified. Comparing deposits of old currency notes solely with the cash balance on the relevant demonetisation date was not a justifiable basis for the addition. The addition, representing only a small proportion of total cash deposits, was deleted.

Agricultural income claimed as exempt was not liable to addition as income from other sources merely on an unsupported allegation of duplicate agricultural expenditure. Where ownership of agricultural land, agricultural produce and the income source were undisputed, and the partnership firm's accounts contained neither agricultural income nor agricultural expenses, entries reflecting drawings from the partner's current capital account did not establish a duplicate claim. The addition for alleged double claiming of agricultural expenditure was deleted.

Commission income from accommodation-entry transactions should be estimated consistently where the admitted nature of transactions and material circumstances remain unchanged across assessment years. A 10% estimate lacks a stated basis where subsequent assessments applied a rate of Rs. 2,000 per crore on materially unchanged facts. Applying the rule of consistency supports using that accepted rate for the relevant assessment year rather than a higher percentage-based estimate.

Section 148 notices issued by jurisdictional Assessing Officers, rather than through the faceless reassessment regime, were treated as inconsistent with Section 151A and the applicable notification. Applying the stated jurisdictional precedent and co-ordinate bench approach, invalid initiation of reassessment also defeated the consequential reassessment and related addition. The deletion of the addition was therefore sustained.

Gross GST revenue for September 2026 distinguishes domestic collections and IGST on imports; after domestic and ICEGATE refund adjustments, net revenue is calculated separately for domestic and customs GST. Cumulative collections through September similarly distinguish gross receipts, refunds and net revenue. SGST reporting compares pre-settlement receipts with post-settlement amounts that include the SGST portion of IGST settled to States and Union Territories. State and Union Territory revenue comparisons exclude GST on imported goods, while April-September domestic collections are split between Central and State formations.

TRQ holders allocated quantities for raw sugar imports may surrender unutilised quantities until 15 October 2026. Surrender requires payment of an amount equal to 0.5% of the CIF value of the surrendered quantity under existing modalities. The extension alters only the surrender deadline; all other conditions governing the raw sugar TRQ allocation and surrender framework remain unchanged.

Minimum Import Price condition on imports of Virgin Multi-layer Paper Board under Chapter 48, Schedule I, and ITC (HS) codes 48059100, 48059200, 48059300, 48109200 and 48109900 is extended until 31 March 2027. The MIP remains INR 67,220 per metric tonne on CIF value, while all other terms and conditions under the prior framework remain unchanged.

Project Jagrook requires stock brokers to display investor awareness messages alongside risk disclosures. Between October 5 and October 31, 2026, website display of both is mandatory, while trading-app display of investor awareness messages is voluntary and risk disclosures are optional where such messages are displayed. From November 1, 2026, brokers must place investor awareness messages on website and trading-app landing pages and display investor awareness messages and risk disclosures on alternate days on trading apps. Stock exchanges and depositories must disseminate, display and implement these requirements.

Royalty paid for technical know-how used in manufacturing should be benchmarked under the Transactional Net Margin Method where the foreign associated enterprise only provides technology and does not undertake manufacturing or sales functions. The Profit Split Method requires both associated enterprises to contribute to profits from the relevant transaction and is generally unsuitable without a unique and valuable contribution by the technology provider alongside the manufacturer. On materially similar prior-year and group-company facts, the Transactional Net Margin Method is the most appropriate method; the arm's length price requires recomputation after the taxpayer receives an opportunity of hearing.

ASI 2024-25 records broad-based growth in registered manufacturing, including establishments, output, Gross Value Added, employment, emoluments, fixed capital, invested capital, net income and net profit. The survey covers specified registered factories, bidi and cigar establishments, certain electricity undertakings, and qualifying large units in State-maintained business registers. Data are collected electronically under the statutory framework for collection of statistics using an establishment-based approach, with quality checks and caution required because the estimates arise from a sample survey.

The fifth Kautilya Economic Conclave will examine economic resilience amid global shocks through discussions on macroeconomic stability, monetary policy, financial stability, investment, fiscal federalism and capital-market development. Its agenda also covers digital economy governance, artificial intelligence, trade fragmentation, strategic autonomy, climate resilience, food systems, demographic change and global health security. Plenaries, parallel sessions and closed-door roundtables will consider policy responses and mobilisation of domestic and foreign capital for long-term investment.