Transfer-pricing comparability of back-office support services - Working-capital adjustment in transfer pricing - Notional interest on associated-enterprise receivables - Arm's length price of associated-enterprise cost allocations Transfer-pricing comparability of back-office support services - Selection of comparables for benchmarking back-office support services rendered to associated enterprises - HELD THAT: - Companies providing specialised engineering or high-end knowledge-process s... ... ...

Stamp-duty valuation of property allotted before enactment of section 56(2)(vii)(b) - Relevance of allotment date and payment of consideration - Applicability of section 56(2)(vii)(b) to an immovable property allotted and partly paid for before the provision was enacted, though the conveyance was subsequently registered HELD THAT: - The contemporaneous allotment letter and banking evidence established that the property had been allotted and part consideration paid before section 56(2)(vii) ca... ... ...

Suppressed business turnover - taxability of embedded profit - Cash-payment disallowance - person-wise and day-wise monetary threshold Suppressed business turnover - taxability of embedded profit - Profit estimation on unrecorded sales - Taxability of alleged unrecorded sales of offals, horns and other by-products generated in the disclosed business-whether the gross receipts or only the profit embedded therein could be assessed - HELD THAT: - On the Revenue's own premise, the alleged rec... ... ...

TP Adjustment - Functional comparability under TNMM - Operating character of business-related receipts in profit level indicator - Current-year comparability in an extraordinary recessionary year - Interest on overdue trade receivables of a debt-free company Intra-group support services - additional evidence and TNMM benchmarking - TP adjustment for support services received from associated enterprises on cost-to-cost basis - HELD THAT: - The additional evidence tendered to demonstrate the be... ... ...

Limitation for consequential assessment after partial appellate remand - Transfer-pricing remand and extension of limitation Validity of the assessment made after a partial appellate remand of comparability issues in transfer-pricing proceedings - HELD THAT: - The earlier appellate order neither set aside nor cancelled the assessment, but partly directed exclusion of comparables and remitted specified comparability questions for fresh examination. It was therefore an order to be given effect ... ... ...

Taxability of the difference between the stamp duty value and purchase consideration of a jointly acquired immovable property u/s 56(2)(vii)(b) - Departmental valuation of jointly acquired property - Consistent valuation of co-owners' interests HELD THAT: - The proviso applicable to section 56(2)(vii)(b) permitted reference to a Valuation Officer where the assessee disputed the stamp duty value on grounds specified in section 50C(2); hence, the valuation mechanism could not be excluded me... ... ...

Notional annual letting value of unsold real-estate stock-in-trade - Arm's length benchmarking of marketing brokerage Notional annual letting value of unsold real-estate stock-in-trade - Prospective operation of section 23(5) - Taxability of notional annual letting value of completed but unsold flats held as stock-in-trade by a builder for the pre-amendment period - HELD THAT: - The completed unsold units formed part of the assessee's stock-in-trade, and the issue stood consistently d... ... ...

Deduction of capital expenditure on scientific research - Research and development building expenditure - Inapplicability of DSIR approval and Form No. 3CL Eligibility of capital expenditure on construction of a research and development building, used for scientific research related to the assessee's business, for deduction under section 35(1)(iv) read with section 35(2) - HELD THAT: - A conjoint reading of section 35(1)(iv) and section 35(2)(ia) allows the whole capital expenditure incur... ... ...

Perquisite taxability of compensation for unexercised employee stock options - Profits in lieu of salary Voluntary compensation for unexercised employee stock options - Perquisite under section 17(2)(vi) - Taxability as a perquisite of voluntary compensation paid on diminution in the value of unexercised employee stock options following the PhonePe divestment - HELD THAT: - A receipt connected remotely with employment does not become salary merely because the employee originally obtained the ... ... ...

Deduction for eligible telecommunication business - Eligible profits from telecommunication operations - Annual telecom licence fee - Asset restoration cost - Tax deduction on domestic roaming charges - Pre-paid distributor discount - Disallowance in absence of exempt income - Compensatory charges under telecom licence - Crystallisation of network site rental expenditure - Arm's-length price of brand royalty - Advertisement, marketing and promotion expenditure - Revenue character of spectrum... ... ...

Double taxation of TP adjustment - Write-back of management support service liability Sustainability of a transfer-pricing adjustment for management support services where the identical liability was stated to have been written back and offered to tax in the subsequent assessment year - HELD THAT: - The arm's length price had already been determined at Nil, and the remaining question was confined to whether the identical liability had actually been offered to tax and retained in the asses... ... ...

TP Adjustment - MAM - Cost Plus Method based on internal comparable - Interest on delayed associated-enterprise receivables Selection of most appropriate method - Cost Plus Method based on internal comparable - Arm's length price of software development services rendered to the associated enterprise-selection of the Cost Plus Method based on an internal comparable as against the Transactional Net Margin Method - HELD THAT: - A traditional method adopted by the assessee cannot be displaced... ... ...

TP adjustment confined to international transactions - Functional comparability for instant-noodle manufacturing - AMP expenditure and Bright Line Test TP adjustment confined to international transactions - Transfer pricing adjustment on the manufacturing segment computed with reference to the assessee's entire operating revenue rather than its international transactions with associated enterprises - HELD THAT: - Chapter X permits redetermination only of income arising from international ... ... ...

Limitation for final assessment order - Transfer pricing comparability of software development service providers - Transfer pricing comparability of IT-enabled service providers Limitation for final assessment order - Retrospective amendment to assessment limitation - Validity of the final assessment order on the ground of limitation - HELD THAT: - The retrospective amendments made by the Finance Act, 2026 to the provisions governing the Dispute Resolution Panel procedure and assessment limit... ... ...

TP Adjustment - Notional interest on overdue receivables of debt-free company - Business expenditure - Employee stock option plan cost TP adjustment for notional interest on outstanding receivables from associated enterprises of a debt-free company - HELD THAT: - The Tribunal found that the assessee was a debt-free company and followed the co-ordinate Bench decision in the assessee's own case[2025 (2) TMI 1788 - ITAT CHENNAI]. In those circumstances, an imputation of interest on outstandi... ... ...

Personal-use disallowance of motor car expenditure - Interest disallowance on interest-free advances - Verification of salary and wage expenditure - Use of third-party statements without cross-examination - Ad hoc disallowance of labour charges Personal-use disallowance of motor car expenditure - Interest on car loans - Disallowance of depreciation, insurance, petrol and diesel expenditure and interest on loans taken for motor cars on account of personal use - HELD THAT: - Where motor cars ar... ... ...

Penalty u/s. 270A for misreporting of income - donation deduction claimed u/s 80GGC - Immunity from penalty under section 270AA - claim withdrawn in the return filed pursuant to reassessment proceedings HELD THAT: - Following the Coordinate Bench decision HIRO MULCHAND TANWANI, AHMEDABAD [2026 (6) TMI 214 - ITAT AHMEDABAD] covering the issue, the Tribunal held that a deduction claim disclosed in the return does not, merely because it is disallowed or withdrawn, establish misreporting absent m... ... ...

Penalty u/s 271I - failure to furnish Form 15CA for foreign remittances - Bona fide belief arising from prospective amendment of Rule 37BB HELD THAT: - The amended Rule 37BB, mandating Form 15CA, operated with effect from 01.04.2016. The assessee's failure to furnish the form at the relevant time was under a bona fide belief founded on the unamended rule, which did not require furnishing of Form 15CA for remittances not chargeable to tax. Such failure could not attract penalty. [Paras 8] ... ... ...

Levy of penalty u/s 270A - Under-reported income - bona fide explanation for delayed filing of return Penalty for under-reporting of income where a Government company filed its return in response to reassessment notice after delay in completion of its mandatory statutory and supplementary audits - HELD THAT: - The assessee's inability to file the original return arose from delay in completion of the audit and finalisation of accounts, a process beyond its control. Its return filed in resp... ... ...

Deductor not deemed assessee in default where payee has paid tax - Verification of Form 26A - Liability of the deductor as an assessee in default for failure to deduct tax on interest paid to HUDCO, where HUDCO had accounted for the interest income and paid tax thereon HELD THAT: - The Tribunal held that, since HUDCO had taken the interest payment into account in computing its taxable income and had paid tax on it, the deductor could not be declared an assessee in default under the first prov... ... ...