🎉 NEW: AI-Powered TaxCorp Platform is Live! Visit New Site Learn More

Highlights

TaxCorp News 
Congress to raise inflation, Maha Kumbh stampede, Ambedkar 'insult' during Budget Session
White House says Trump tariffs on Canada, Mexico and China will come Saturday. No word on exemptions
Never talks about people's issues, spreads conspiracy theories: Congress hits back at PM Modi
Second federal judge orders temporary pause to Trump administration efforts to freeze funding
ATF price hiked by 5.6 pc, commercial LPG rate down Rs 7 per cylinder
Monthly Review of Accounts of Government of India upto December, 2024 (FY2024-25)
Sitharaman takes Tablet in red pouch to present paperless budget
FIU-IND imposes monetary penalty of Rs. 9 crore 27 lakhs on Virtual Digital Asset Service Provider Bybit Fintech Limited (Bybit)
Markets open higher ahead of Budget presentation
NATIONAL SCHEDULE
The Most Promising AI Coins for Investors | Dawgz AI on the Forefront
Budget for world's fastest-growing major economy: Key numbers to be watched
IRIS 9MYoY Revenues up 29%, 9MYoY Net profits up 155%
Finance Minister Nirmala Sitharaman meets President ahead of Budget speech
Cabinet clears Union Budget 2025-26
Re Sustainability and Recycling Private Limited & Aarti Circularity Limited Announce ?100 Cr Initial Investment to Transform Plastic Recycling
TECNO Teases POVA's Delta Shape Star of Light in the Galaxy!
Top 5 Next Crypto to Explode: Watch Out For These Coins
Nirmala Sitharaman creates history with 8th consecutive budget
Budget focussed on driving growth, inclusive development: Sitharaman
Page 1 of 5 (100 items)< Prev12345Next >
ITAT : Addition Under Section 69C Restricted to Profit Element Where Purchases Substantiated by Documentary Evidence

HC : Madras High Court Upholds Section 69 Addition for Unexplained Investment Due to Lack of Registered Title; Dismisses Writ Challenging Assessment and Penalty Orders

ITAT : Hyderabad ITAT Upholds Weighted Deduction for R&D Expenditure Despite Delay in Furnishing Form 3CLA—Substantial Compliance Under Section 35(2AB) Recognized

ITAT : Mumbai ITAT Upholds Reassessment Post-Search under Revised Section 147: AO’s Reliance on “Information” Deemed Sufficient for Jurisdiction

ITAT : ITAT Mumbai Remands Share Capital Addition Under Section 68: CIT(A) Faulted for Not Inquiring Creditworthiness and Genuineness Despite AO’s Detailed Findings in High-Premium Share Allotment

ITAT : Mumbai ITAT Upholds CPC’s Power to Adjust Return Based on Tax Audit Report under Section 143(1)(a)(iv), But Strikes Down Mechanical Section 14A Disallowance Absent AO’s Dissatisfaction

ITAT : Mumbai ITAT Rules Ex-Gratia Severance from Employer’s India Exit as Non-Taxable Capital Receipt, Not ‘Profits in Lieu of Salary’

ITAT : Mumbai ITAT Rules Repayment of Business Liabilities Not Taxable as Unexplained Expenditure under Section 69C in Absence of Actual Outflow or P&L Deduction

ITAT : Mumbai ITAT Affirms Allowability of Business Development Expenses and Depreciation on Director-Registered Vehicles in Absence of Contradictory Evidence

ITAT : ITAT Chennai Rules Web Hosting Fees Not Royalty: No Right to Use Equipment or IP Transferred Under India-USA DTAA

ITAT : Chennai ITAT Exonerates Sundaram Finance from Penalty under Section 270A: Bona Fide Reliance on Jurisdictional High Court Precedent Shields Assessee on Bad Debt Recovery Issue

ITAT : Delhi ITAT Clarifies: No Doctrine of Merger Between Orders u/s 143(1) and 143(3); Dismisses Appeal for Lack of Grievance

ITAT : ITAT Chennai Orders Grant of Section 80G Approval to Trust Engaged in Rural Empowerment and Skill Development Despite Revenue Generation

ITAT : Mumbai ITAT Allows Full Deduction for NBFC’s Debenture Issue Expenses Under Section 37(1); Disallows Amortisation Under Section 35D

ITAT : ITAT Ahmedabad Quashes Disallowance under Section 37: Death of Proprietor and GST Cancellation Not Sufficient Grounds for Purchase Addition

ITAT : Mumbai ITAT Rules Rs 50 Lakh Development Rights Payment as Capital Gains, Not “Other Sources”; Section 50C Inapplicable in Absence of Land Transfer

ITAT : Chennai ITAT Quashes Reassessment for Failure to Issue Mandatory Section 143(2) Notice Despite Belated Return Filed in Covid Circumstances

ITAT : Mumbai ITAT Affirms SEBI-Registered VCF’s Entitlement to Multiple Section 10 Exemptions on Distinct Income Streams

ITAT : Chennai ITAT Quashes PCIT’s 263 Order: Reassessment Restored as Mutual Fund Dividend Taxed Appropriately and No Sham Proven

ITAT : Chennai ITAT Quashes Fresh Addition by AO Exceeding Tribunal’s Remand Scope; Restricts AO to Tribunal’s Directions Only

ITAT : Mumbai ITAT Orders Fresh Examination on Taxability of Software Sales by McAfee Singapore, Stresses No Royalty Without Copyright Transfer

ITAT : Retrospective Application of Amended Rule 11UA for Share Valuation Disallowed under Section 56(2)(vii)(c); Additions Set Aside

ITAT : ITAT Holds Deferred Revenue for Unexpired Warranty Period Recognizable Over Warranty Tenure; Affirms Consistent Accounting Policy as Per AS-9 and ICDS-IV

ITAT : Delhi ITAT Rules Penalty under Section 271(1)(c) Inapplicable Where Full Tax Paid Prior to Notice under Section 148 – Assessment Accepted Without Variation

ITAT : Mumbai ITAT Special Bench Affirms 16-Year Reassessment Limitation for Non-Residents under Section 149(1)(c) in Foreign Asset Cases; Addition Deleted for Lack of Source Provenance

ITAT : Delhi ITAT Invalidates Reassessment for Lack of New Evidence; Reopening Held as Mere Change of Opinion Where Assessment Was Previously Concluded After Survey

ITAT : Mumbai ITAT Upholds Section 10(46) Exemption for Prior Period and Ancillary Regulatory Incomes: Nature of Income Prevails Over Timing and Classification

HC : Madras High Court Upholds Validity of Assessment Order under Section 143(3) r.w.s 153A, Rejects Assessee’s Plea on Settlement Commission Jurisdiction Post-Finance Act, 2021

ITAT : Delhi ITAT Holds Section 56(2)(viib) Inapplicable to Oyo Hotels—Share Issuance to Existing Shareholders with RBI-Valued Pricing Not Taxable as Unaccounted Money

ITAT : Mumbai ITAT Affirms: Fair Market Value of Surrendered Tenancy Rights Constitutes Cost of Acquisition for Redevelopment Flats

AAR : Karnataka AAR Restricts ITC on Factory Canteen Services to Statutory Portion Borne for Regular Employees; Contract Labour and Employee-Recovered Costs Excluded

SC : Supreme Court Declines to Entertain Constitutional Challenge to Section 16(2) CGST Act, Upholds High Court’s Direction to Pursue Statutory Appeal, but Expressly Reserves Assessee’s Rights

AAR : Brake Hoses Used in Vehicle Braking Systems Classified as Vulcanized Rubber Tubes under HSN 4009; Haryana AAAR Rules 18% GST Applicable, Overturning Earlier AAR Ruling

HC : Allahabad HC Quashes ITC Blocking for Lack of “Reason to Believe” Under Rule 86-A of UP GST Rules in Mohan Milkfoods Case

HC : Bombay High Court Sets Aside GST Refund Rejection for IT Exporter Due to Absence of Reasoned Order; Remands Case for Fresh Adjudication

HC : Gauhati High Court Quashes GST Demand on Bona Fide Purchaser Where Supplier Defaults on Tax Deposit, Reiterates Department’s Remedy Against Defaulting Seller

HC : Kerala High Court Upholds Detention of Arecanut Consignment and Vehicle Pending Title Adjudication Under GST Law

HC : Kerala High Court Rules ISD Registration Not Mandatory for ITC Distribution Prior to April 1, 2025; Quashes GST Demand and Penalty on Cross-Charge Transactions

HC : Gauhati High Court Quashes GST Assessment for Lack of Proper Show Cause Notice: Summary DRC-01 Held Insufficient to Initiate Proceedings under Section 73

HC : Orissa High Court Quashes GST Appellate Order for Failure to Consider Assessee’s Timely Reply on Limitation Issue

HC : Gauhati High Court Affirms Retrospective Penalty on Partners for GST Evasion: Partners Held Personally Liable under Section 122(1A) CGST Act

HC : Allahabad High Court Declares Arrest and Remand under CGST Act Illegal for Absence of Mandatory DIN and Procedural Safeguards

GSTAT : GSTAT Upholds Rs. 13.61 Crore Profiteering by Lifestyle International Pvt. Ltd. for Failing to Pass on GST Rate Reduction to Customers; No Interest or Penalty Levied

GSTAT : GSTAT Delhi Affirms No Profiteering by Arun Excello Constructions LLP in “Compact Homes-Narmada” Project Due to Absence of Incremental ITC Benefit

HC : Gauhati High Court Upholds Validity of Consolidated Notices and Orders for Multiple Financial Years under GST; Assessees' Plea on Prejudice and Limitation Rejected

HC : Madras High Court Nullifies GST Assessment on Seigniorage Fees, Directs Fresh Proceedings Subject to Supreme Court Verdict

HC : Bombay High Court Declares Consolidated GST Show-Cause Notice and Recovery Order Void for Lack of Jurisdiction—Permits Fresh Proceedings under Proper Provisions

HC : Madras High Court Remands GST Penalty Order under Section 74 for Fresh Review; Opportunity Allowed to Prove Genuine Supply and Wrongful Invocation

HC : Madras High Court Quashes ITC Demand, Orders Fresh Inquiry Where Supplier’s Tax Compliance is Evident Despite Missing Transport Documents

HC : Madras High Court Quashes ITC Denial for Late Return Filing in Light of Section 16(5) Amendments; Orders Passed Under Section 16(4) Limitation Held Unsustainable

HC : Madras High Court Nullifies GST Demand and Penalty under Section 74 Owing to Lack of Hearing and Prima Facie Non-Applicability of Registration Threshold

ITAT : Madras High Court Quashes Best Judgment Assessment under Section 62, Directs Revenue to Reassess Considering Subsequently Filed Returns

HC : Madras High Court Invalidates Assessment Order Issued Against Deceased Taxpayer; Permits Fresh Proceedings Against Legal Heirs

HC : Meghalaya High Court Denies Writ Relief on GST Annuity Demand, Directs Jorabat Shillong Expressway Ltd. to Exhaust Statutory Appeal Route

HC : Gauhati High Court Restores GST Registration Citing Failure to Issue Proper 30-Day Show Cause Notice under Rule 21A(2A)(b) for Violation of Rule 10A

AAR : Kerala AAAR Confirms GST Liability on Wetland Conversion Fees, Restricts Advance Ruling to Prospective Transactions Only

HC : Rajasthan High Court Upholds DGGI Authority to Seal Premises and Attach Bank Accounts in Absence of Assessee’s Cooperation During CGST Investigation

HC : Allahabad High Court Upholds Validity of CGST Authority’s Show-Cause Notice under Health Security and National Security Cess Rules Despite Rubber Stamp Error: Pan Masala Manufacturer Denied Pre-emptive…

GSTAT : GSTAT Delhi Declares Procurement Support Services from Dow Europe as 'Import of Services', Rejects Intermediary Service Claim for IGST Refund

HC : Delhi High Court Upholds Validity of Consolidated Show Cause Notices under Section 74 CGST Act for Multiple Years in ITC Fraud Cases

Income tax – Sections 115JB - ITAT Delhi Holds Proceeds from Renewable Energy Certificates to be Capital Receipts; Not Taxable as Revenue Income under Income Tax Act - The ITAT, Delhi, has reaffirmed that sale proceeds from Renewable Energy Certificates (RECs) are to be treated as capital receipts and are not taxable as revenue income. The Tribunal also clarified that RECs, by their legal character, do not fall within the ambit of “carbon credits” as defined in section 115BBG and, therefore, cannot be taxed under this provision. The Tribunal further held that such receipts are to be excluded from the calculation of book profits under section 115JB. In cases where the DRP has issued binding directions, strict compliance is required from the Assessing Officer, and any disregard of such directions renders the assessment order unsustainable. Enhanced or corrected claims for deduction under section 80-IA, if already claimed, must be duly examined on merits as per judicial precedents.

Income tax – Sections 94B - ITAT Chennai Rules Thin Capitalisation Norms under Section 94B Cannot Discriminate Against Indian Subsidiaries Borrowing from Denmark: Disallowance Struck Down under India-Denmark DTAA - The ITAT Chennai has decisively held that the thin capitalisation restriction under Section 94B, which applies only to non-resident AE borrowings and not to resident AE borrowings, is discriminatory when tested against the non-discrimination clause in Article 24(4) of the India-Denmark DTAA. Accordingly, the entire disallowance made under Section 94B was deleted. The decision stresses that unless the DTAA contains a specific carve-out permitting thin capitalisation rules, such restrictions cannot override treaty protection. Taxpayers with similar treaty protection and facts may rely on this decision to challenge Section 94B disallowances.

ITAT Bangalore Upholds Exclusion of High-Turnover and Functionally Dissimilar Comparables in Software and Marketing Support Transfer Pricing - The ITAT Bangalore’s decision reaffirms that in transfer pricing comparability analysis, both the turnover filter and functional similarity are paramount. Companies with substantially higher turnover than the assessee, or those engaged in multi-functional or product-based activities without reliable segmental data, are not appropriate benchmarks for captive service providers. The Tribunal’s approach mandates that comparables must be similar not only in terms of functions but also in scale and segmental focus. Taxpayers should meticulously review their comparables in light of these principles and be prepared to justify their selections with segmental and functional data.

Income-tax - Sections 144C(13), 144B - ITAT Delhi Remands TP Adjustment on Intra-Group Management Fees: Commercial Expediency Not to Be Questioned if Service Rendered; Factual Verification Directed - The ITAT has clarified that while the TPO is not empowered to challenge the commercial rationale of an expense shown to have been incurred for business purposes, the taxpayer must establish, through credible and contemporaneous evidence, that the alleged intra-group services were actually rendered. The onus is on the assessee to prove the nature and extent of services received from the AE. Inadequate substantiation will result in the matter being remanded to the lower authorities for proper verification. Taxpayers must be prepared to furnish detailed and transaction-specific documentation to support their claims in transfer pricing matters.

Income Tax - Sections 143(3), 144C(13), 144B - ITAT Delhi Directs Inclusion of Previously Accepted Comparables in Transfer Pricing Assessment for Lubricants Manufacturer - Based on the current ruling, it is actionable for both taxpayers and the Department to ensure that comparables found functionally similar and accepted in prior years should ordinarily be continued in subsequent years for transfer pricing analysis, unless there is a demonstrable change in facts or circumstances. The Tribunal has reinforced the need for consistency and fairness in the selection of comparables, particularly when Revenue has not raised any objection in the past.

Income Tax - Sections 143(3), 144C(13), 144B - Delhi ITAT Directs TPO to Apply Internal CUP for Benchmarking Interest on NCDs Issued to AEs: Ignores Inadmissible TP Adjustment on Opening Balances - The ITAT has categorically directed that the TPO must apply the Internal CUP method for benchmarking the interest paid on the PPFC03BV Bond issued to the AE during the relevant year. The Tribunal’s decision reinforces that transfer pricing adjustments cannot be sustained by overlooking relevant internal comparables, especially when such comparables have been accepted in other assessment years and are specifically directed to be considered by the DRP. The TPO is required to reassess the transaction using Internal CUP as the Most Appropriate Method and pass a reasoned, speaking order.

Income tax – Sections 144C, 153 - ITAT Delhi Quashes Final Assessment Orders Exceeding Section 153 Limitation Despite Section 144C Non-Obstante Clause in Transfer Pricing Cases - The ITAT Delhi has unequivocally held that, in cases involving transfer pricing and the DRP procedure under Section 144C, the final assessment order must be passed within the limitation period stipulated under Section 153. The non-obstante clause in Section 144C(13) does not override or exclude the operation of the limitation period. Final assessment orders passed beyond the statutory timeline are invalid and must be quashed. Assessees and tax practitioners must vigilantly track the expiry of the Section 153 time limit, irrespective of the DRP and draft order process, to ensure legal compliance and protect their rights.

Income Tax - Section 271(1)(c) - ITAT Delhi Directs Amortization of Goodwill to be Treated as Non-Operating Expense Under TNMM, Rejects DRP’s Interpretation - In this decision, the ITAT Delhi has unequivocally held that, for transfer pricing analysis under the TNMM, amortization of goodwill arising from a slump sale constitutes an extraordinary expense and must be treated as non-operating while computing the PLI. The Tribunal has directed the AO/TPO to exclude such amortization from the operating costs for the relevant assessment year and to recompute the transfer pricing adjustment accordingly. Assessees facing similar facts should ensure that extraordinary items like goodwill amortization are appropriately characterized in the PLI computation and should contest any contrary adjustment by lower authorities with reference to this order.

FEMA Adjudication Upheld Despite Customs Settlement: Tribunal Clears Exporters Over Foreign Commission Issue Due to Lack of Repatriation Obligation and Hearsay Evidence - In light of the above findings, the Tribunal allowed the appeals and quashed the penalties, holding that the commission paid overseas by a foreign buyer to a foreign agent does not represent export proceeds due to the Indian exporter under FEMA. The Tribunal further concluded that the principal evidence relied upon by the authorities was hearsay and inadequate to sustain the alleged violations.

Appellate Tribunal Upholds Liability for Import Documentation Default Despite 15-Year Delay; Substantial Reduction in Penalties for Company and Managing Director Under FEMA - The Tribunal’s decision makes it clear that a prior notice, even if substantially removed in time from the date of adjudication, places a duty on the recipient to preserve and, if required, produce relevant records. The inability to do so, especially for a company engaged in regular imports, cannot be excused on the ground of delay when an opportunity to comply was provided at a proximate point in time. Furthermore, key managerial personnel must exercise demonstrable due diligence to avoid personal liability under Section 42 of FEMA. The proportionality of penalty remains subject to judicial scrutiny, permitting relief in appropriate cases without undermining the findings of contravention.

Tribunal Affirms FEMA Violation for Inadequate Foreign Exchange Utilisation, Disallows Third-Party Adjustment, and Reduces Penalty - The Tribunal’s decision affirms that importers must strictly adhere to the declared purpose for which foreign exchange is acquired under FEMA, and deviations—such as third-party adjustments without explicit RBI approval—constitute contraventions. The penalty, although upheld, was reduced in consideration of the circumstances. Importers must ensure compliance with FEMA’s requirements, and any deviation must be supported by clear legal provisions or RBI permissions to avoid penal consequences.

Income tax – Sections 144C, 153 - ITAT Delhi Quashes Assessment Order Passed Beyond Section 153 Limitation Despite Pending Supreme Court Proceedings - The ITAT Delhi has set aside the final assessment order for AY 2021-22, holding it to be invalid as it was passed beyond the statutory limitation period under section 153, even where related issues are pending before the Supreme Court. The Tribunal’s order is actionable: Revenue officers and assessees must strictly adhere to the limitation timelines prescribed by section 153, regardless of any ongoing higher judicial scrutiny unless there is a specific stay or contrary precedent from a higher court.

Income tax – Sections 47(iv) - Buy-Back of Shares by Indian Subsidiary Held as Corporate Reorganization under India–Netherlands DTAA—Capital Gains Not Taxable in India - Based on the majority decision, the ITAT Delhi held that a buy-back of shares by an Indian subsidiary from its foreign parent, constituting a significant capital restructuring but retaining substantial control in the parent, qualifies as a “corporate reorganization” under Article 13(5) of the India–Netherlands DTAA. Consequently, the capital gains arising from such transaction are not taxable in India. The key actionable takeaway for foreign holding companies is to analyze the applicability of treaty provisions for similar transactions and maintain documentary evidence demonstrating the reorganization nature of buy-back events.

Income tax – Sections 36(1)(iii) - ITAT Mumbai Upholds Interest Deduction for Tata Steel’s Corus Acquisition; Deletes Addition on Alleged Unaccounted Mining Profits - The ITAT Mumbai’s decision solidifies the principle that where borrowed funds are demonstrably used for the purpose of business expansion, including through acquisition in the same industry, interest deduction under Section 36(1)(iii) is allowable. Furthermore, in the absence of fresh or contradictory evidence, additions based on allegations of illegal mining cannot be sustained when production figures are corroborated by statutory records and past favourable orders exist.

Income tax – Sections 144C, 153 - ITAT Delhi Quashes Tax Assessments Passed Beyond Limitation: Sections 144C & 153 Held Mutually Inclusive Despite Pending Apex Court Reference - The Tribunal’s decision unequivocally establishes that, for the purposes of determining the limitation period for passing final assessment orders under section 144C(13), both section 144C and section 153 must be read harmoniously. The non obstante clause in section 144C does not exclude the entire operation of section 153, and adherence to statutory timelines is mandatory. Assessment orders passed beyond the combined limitation prescribed under these provisions will be rendered without jurisdiction and liable to be quashed. Tax authorities and assessees alike must meticulously compute limitation periods with reference to both sections to ensure compliance.

ITAT Bangalore Rules on Upper Turnover Filter and Notional Interest: Large Companies Excluded from Comparables; LIBOR + 200bps Set for Receivables in Absence of Inter-Company Agreement - The ITAT Bangalore has reaffirmed that comparability analysis in transfer pricing must account for turnover differences to ensure meaningful benchmarking, especially in the software development services sector. Companies with turnovers significantly larger than the tested party’s cannot be mechanically selected as comparables. For outstanding receivables, the Tribunal stressed the necessity of proper documentation to substantiate agreed credit terms; absent such evidence, a moderate notional interest rate (LIBOR + 200bps) is to be applied. Assessees should place emphasis on maintaining robust inter-company agreements and contemporaneous documentation for all material transaction terms.

Income Tax - Sections 143(3), 144C(13) - ITAT Delhi Invalidates Final Assessment Order for Breach of Limitation under Section 144C; Directs Exclusion of Functionally Dissimilar Comparables in Transfer Pricing - The ITAT, Delhi, has categorically held that comparables functionally dissimilar to the tested party’s business activity, especially those engaged in high-end software development or unrelated digital activities, must be excluded from the final set for transfer pricing purposes. Crucially, the final assessment order passed after the expiry of the prescribed limitation period under Section 144C(13) is invalid and unenforceable. Assessees must rigorously apply functional, turnover, and other relevant filters to ensure only appropriate comparables are considered, and should vigilantly monitor statutory timelines for assessment procedures.

Income tax – Sections 144B, 144C, 153 - ITAT Delhi Quashes Final Assessment Order for Breach of Statutory Limitation: DRP Proceedings Held Integral to Assessment Timeline Under Section 153 - Based on the above findings, the Tribunal conclusively quashed the final assessment order for being passed beyond the period of limitation prescribed by section 153, read with section 144C. The Tribunal’s ruling is actionable and mandates that assessment orders, even if routed through the DRP, must strictly comply with the outer limitation stipulated under section 153.

Income Tax - Section 254 - ITAT Bars Revenue from Excluding Previously Accepted Comparable at Tribunal Stage: Segmental Data of Onward Technologies Ltd. Key to Decision - The ITAT’s decision unequivocally establishes that once a comparable has been accepted by both the TPO and CIT(A) after due examination, the Revenue cannot subsequently seek its exclusion before the Tribunal based on functional differences. This ensures finality and consistency in the comparability analysis, while also upholding the integrity of the transfer pricing process. Assessees can rely on the comparables accepted at the lower levels unless there is a manifest error or new evidence brought on record.

Tribunal Upholds Departmental Appeal Under SAFEMA: Share Allotment in Foreign Entity Amounts to Direct Investment, Partial Seizure Sustained - The Tribunal has decisively held that the departmental appeal under Section 37A(5) is maintainable, reinforcing the principle that statutory interpretation must not defeat the rights of parties to challenge orders. It was further established that subscription to shares of a foreign company—even if unpaid—constitutes a foreign security under FEMA, and is not mere paper. The seizure of equivalent value can only be sustained against those currently holding the foreign security. The impugned order was modified accordingly: seizure was restored only against the property of the daughter and son, while assets in the names of the father and deceased wife were released.

SEBI Bars REL and Promoter for Non-Disclosure and Misleading Financials: Foreign Confidentiality Cannot Override Indian Securities Law Mandates - The decision underscores that listed entities operating in the Indian securities market are under a non-negotiable obligation to maintain and furnish all relevant information, irrespective of any private confidentiality or foreign data protection constraints. Companies consolidating overseas subsidiaries’ results into their financials must ensure full transparency, including the continuous maintenance and timely disclosure of underlying subsidiary data. Non-compliance, obstruction, or misleading disclosures will invite regulatory action, including restrictions on dealing in securities and personal liability for key managerial personnel.

Delhi High Court Sets Aside Arbitral Award for ADC Dispute: Tribunal Found to Have Exceeded Contractual Terms and Granted Relief Without Proper Evidence - The Delhi High Court set aside the arbitral award on the grounds that the Tribunal exceeded its mandate by altering the contract’s terms, failed to rely on proper evidence for quantification, and rendered a contradictory award. Practitioners must ensure that arbitral awards strictly adhere to contractual terms and are based on cogent evidence, as deviation is likely to be struck down for patent illegality.

Bombay High Court Directs State to Refund Octroi to SEZ Developer; State’s Inaction Held Contrary to SEZ Policy Despite Absence of Enabling Rules - In this case, the Bombay High Court clarified that while municipal authorities cannot be directed to refund taxes in the absence of enabling legislation, the State Government, which had committed to an exemption in its own policy and admitted as much in court, was duty-bound to honor that commitment. The actionable takeaway is that SEZ developers have a right to enforce State policy commitments where such commitments are not honored through necessary legislative or administrative action, and may seek remedies directly against the State Government for reimbursement in such scenarios.

Delhi High Court Holds Coal Beneficiation May Constitute ‘Manufacture’ for Cost Audit Purposes; Quashing of Prosecution Rejected Pending Trial Evidence - Based on the analysis of Supreme Court judgments and statutory provisions, the Delhi High Court held that coal beneficiation, particularly through wet processes, may constitute “manufacture” or “production” for the purposes of cost audit obligations under the Companies Act, 2013 and the Companies (Cost Records and Audit) Rules, 2014. The Court dismissed the petitioner’s plea for quashing the criminal complaint, clarifying that the determination of the true nature of the activity—manufacture/production or mere processing—requires evidence and adjudication at trial.

NCLAT Upholds Binding Nature of Sanctioned Scheme: Assignment of Creditors’ Claims to 63 Moons Group Precludes Separate Civil Suits Against Consenting Brokers - Based on the above, the NCLAT dismissed the appeal, holding that the sanctioned scheme—already judicially affirmed—binds all specified creditors, including dissenters. The appellants are precluded from pursuing separate civil proceedings in respect of claims covered under the scheme, as those claims are now solely vested with the 63 Moons Group following the assignment.

Calcutta High Court Clarifies: Winding Up Proceedings Can Be Transferred to NCLT Unless Irreversible Stage is Reached—Unpaid Official Liquidator Expenses Not a Bar - The Division Bench of the Calcutta High Court upheld the orders transferring the winding up proceedings and connected applications to the NCLT. It has been conclusively held that unresolved claims for services rendered under the Official Liquidator do not, on their own, prevent the transfer of winding up matters, unless the winding up has reached an irreversible or irretrievable stage. Parties with statutory claims retain the right to pursue those claims before the NCLT post-transfer.

Sections 213, 212 of the Companies Act, 2013 - NCLAT Upholds Directors’ Liability for Fraudulent Transfer of Overseas Subsidiary Shares without Consideration; Sets Aside Direct SFIO Probe, Refers Investigation to Central Government - Given the appellants’ inability to provide a satisfactory and credible explanation for the transfer of subsidiary shares without consideration and the failure to establish how the penalty to Aero Steel was settled, the NCLAT upheld the Adjudicating Authority’s direction requiring the directors to contribute to the assets of the corporate debtor. Furthermore, the appellate tribunal clarified that the Tribunal cannot directly order an SFIO investigation and appropriately referred the matter to the Central Government for further investigation as per the Companies Act, 2013. This decision is actionable in nature, highlighting the need for directors to maintain transparent records and proper documentation for all major transactions, especially during insolvency proceedings.

NCLAT Affirms Limitation Bar and Dismisses Fresh Grounds in Directorship and Shareholding Dispute: Appellant’s Challenge to 2012-2013 Corporate Actions Time-Barred, Valuation Exercise Upheld - The NCLAT’s decision reiterates that challenges to corporate actions such as removal from directorship and share allotments must be brought within the statutory limitation period, commencing when the aggrieved party first becomes aware of the impugned acts. Attempts to raise new grounds for the first time in appellate proceedings will not be entertained, and parties must avail themselves of all opportunities provided at the original stage, particularly in matters involving valuation of shares. The appeal was accordingly dismissed in its entirety.

Supreme Court Clarifies: Derivatives Above Position Limits Not Voided; No Proof of Manipulation in RPL Promoter’s Futures Trades - The Supreme Court’s decision affirms that exceeding position limits under the 2001 SEBI Circular does not void derivative contracts but mandates disclosure and penalizes only non-disclosure. It also holds that a breach of position limits by way of non-disclosure can attract penal action but does not amount to fraud or manipulation per se, absent tangible evidence of market abuse. The Court’s finding that there is no requirement for a perfect hedge and that legitimate market conduct—such as selling to capitalize on price increases—does not constitute manipulation sets a high threshold for establishing fraud or manipulation under SEBI’s anti-fraud regulations. This approach emphasizes the need for clear, cogent evidence before penalizing market participants for complex trading strategies.

Corporate Voting Rights Dispute: NCLAT Allows EOGM but Stays Implementation of Resolutions Pending NCLT Decision on Shareholder Authority - In summary, the NCLAT disposed of the appeal by allowing the EOGM to take place, thereby upholding corporate democracy and shareholder rights, but expressly directed that implementation of any resolution passed at the EOGM be kept in abeyance pending the outcome of the company petition before the NCLT. This ensures that the rights of the parties are preserved and that no irreversible actions are taken until the fundamental questions regarding the corporate shareholder’s voting authority and amendments to the Articles are judicially resolved.

Supreme Court Upholds Expansive Supervisory Powers of Election Commission Under Article 324 and Section 21(3) RP Act: Special Electoral Roll Revision and Documentation Regime Validated - The Supreme Court’s decision affirms that the Election Commission enjoys wide-ranging supervisory and procedural powers for electoral roll management, provided these are exercised within the legislative framework. Special revisions, documentation requirements, and inquiries into citizenship undertaken by the Commission are valid and constitutionally sound, so long as they are rooted in statutory authority and rational criteria.

Bombay High Court Upholds Bona Fide Sale Post-Winding Up Petition: First Transaction Validated Under Section 536(2); Second Private Transfer Excluded - The Bombay High Court, through this decision, allowed the interim application in part by validating only the first transaction under Section 536(2) of the Companies Act, 1956, and dismissed the Official Liquidator’s report as far as it sought to challenge this transaction. The second, purely private, transaction was excluded from the scope of these proceedings, with the Court leaving open the possibility of action against the ex-directors in respect of any statutory dues, should the relevant authorities choose to pursue such action.

NCLAT Upholds Dismissal of Interim Relief, Orders Status Quo on Asset Sale and Fresh Merits Hearing on Related Applications in Oppression and Mismanagement Dispute - In sum, the NCLAT affirmed the dismissal of IA No.21/2023, declining to interfere with the EOGM or blanketly restrain asset disposal. However, the Tribunal continued the status quo order on asset sales to protect the interests of stakeholders until final resolution of the main petition. Additionally, the Tribunal mandated that interlocutory applications relating to earlier incidents be reconsidered afresh and decided on their own merits following a fair hearing.

Calcutta High Court Affirms Bar on Civil Courts in Director Removal Dispute; Sets Aside Ex Parte Injunction for Want of Reasoned Order - The Calcutta High Court allowed the appeal, setting aside the ex parte ad interim injunction that had restrained the company from proceeding under Section 169 of the Companies Act, 2013. The Court held that only the NCLT, and not the civil court, could entertain disputes regarding removal of directors, irrespective of shareholding status. Furthermore, any interim relief—particularly of an ex parte nature—must be supported by a reasoned and case-specific judicial application of the settled legal tests, failing which such orders are unsustainable.

Calcutta High Court Rules Post-Withdrawal Transposition Impermissible: Stringent Limits on Review and Representative Capacity in Oppression and Mismanagement Appeals - The Calcutta High Court’s decision firmly establishes that transposition of parties under Order XXIII Rule 1-A CPC requires an active application pending at the time of withdrawal or abandonment of proceedings; post-withdrawal applications for transposition are not maintainable. The Court also clarified that appeals under Section 10F of the Companies Act, 1956, are available only to persons individually aggrieved and not by way of representative capacity for non-appellants. The scope of review remains strictly limited to patent errors or new evidence, not as a means to reopen concluded matters or to circumvent procedural defaults. Assessees and parties must, therefore, take timely procedural steps and cannot rely on review to remedy lapses or omissions after the underlying proceeding has been terminated.

Supreme Court Declines to Interfere: Company Court’s Authority under Section 446(2) Upheld, MIDC’s Differential Premium Claim Rejected in Liquidation Transfer Case - The Supreme Court’s refusal to intervene upholds the High Court’s clear delineation of the Company Court’s powers under Section 446(2) of the Companies Act, 1956, affirming that such courts are empowered to decide all claims and questions relating to the assets of companies in liquidation. This includes the power to determine the character of transfers (voluntary or involuntary) and the consequent liabilities, such as differential premium or extension charges.

Calcutta High Court Quashes Look Out Circular Post-Investigation: Upholds Right to Travel Abroad under Article 21 Absent Pending Prosecution - The Calcutta High Court set aside the Single Judge’s order and quashed the Look Out Circular, holding that its continuation after the completion of the SFIO investigation and in the absence of any pending prosecution or court proceedings was arbitrary and disproportionate. The Court’s decision was conditioned upon the appellant providing a notarized affidavit in the prescribed form, ensuring future cooperation with the authorities if required. This decision firmly reinforces the requirement that any restriction on the right to travel abroad must not only be based on concrete material but must also be proportionate and the least restrictive means available.

Bombay High Court Clarifies Discretion in Penalty Quantification Under Section 39(5) of Companies Act: Technical Breach in Return of Allotment Attracts Mitigated Joint and Several Penalty - The Bombay High Court’s decision establishes that the penalty provisions under Section 39(5) of the Companies Act, 2013 do not operate in a mechanical fashion. Adjudicating authorities must evaluate the proportionality of the penalty by considering the nature, gravity, and circumstances of the default, as mandated by Rule 3(12) of the Companies (Adjudication of Penalties) Rules, 2014 and in line with Supreme Court precedent. In cases of technical or minor breaches—such as failure to separately certify an annexure when the main form is affirmed—penalty may be warranted but should be mitigated. Additionally, unless specifically justified, penalties should be imposed jointly and severally and not multiplied across all directors.

Supreme Court Stays Prior Orders to Expedite Investor Settlement Scheme; Time-Bound Escrow Deposit Mandated - The Supreme Court has, by this order, stayed the operation of impugned orders to smoothen the path for implementing the court-approved settlement scheme for investors. It directed designated courts and authorities to take all necessary steps without delay and prescribed a strict two-week timeline for the transfer of the settlement funds to the escrow account post de-freezing. The order offers an actionable roadmap for the prompt resolution of investor claims under the approved scheme.

Calcutta High Court Quashes Bank’s Fraud Classification: Reliance on Discredited Audit Report and Undisclosed Lenders’ Meeting Violates Natural Justice - The Calcutta High Court’s order unequivocally sets aside the show cause notice and the fraud classification order, on the basis that the decision was predicated on previously discredited material and undisclosed information from the Joint Lenders Meeting, in violation of the principles of natural justice. The bank is permitted to undertake fresh proceedings, provided that they adhere strictly to legal requirements, including disclosure of all relied-upon material and provision of a fair opportunity to respond.

NCLAT Upholds Waiver of Threshold Requirement under Section 244 in Guarantee Company: Prima Facie Oppression and Mismanagement Sufficient for Relief - On a careful appraisal of the impugned order and the submissions advanced, the NCLAT dismissed the appeal, holding that the adjudicating authority had articulated sufficient prima facie reasons for the grant of waiver under Section 244. These reasons included the persistence of alleged acts of oppression and mismanagement, the challenge to membership actions, and the violation of the Articles of Association. The order, therefore, stands affirmed, and the company petition may proceed without requiring compliance with the statutory threshold.

Sections 241, 242 of the Companies Act, 2013 - NCLT Ahmedabad Orders Restoration of Corporate Governance Amidst Deadlock and Mismanagement in Closely Held Company - The NCLT’s decision underscores that in cases where company management is paralyzed due to deadlock and mutual distrust, even without concrete proof of oppression, the Tribunal can intervene under section 242 to address mismanagement and protect the company’s interests. Actionable steps include facilitating access to records and ensuring ongoing statutory compliance, while purely financial or time-barred reliefs may be declined unless substantiated by cogent evidence.

Supreme Court Upholds Void Nature of Post-Winding-Up Property Transfers; Delay Condoned but No Relief Granted to Appellant - The Supreme Court’s order confirms that any disposition of company property after the commencement of winding up proceedings, absent explicit court validation, is void in law as per Section 536(2) of the Companies Act, 1956. Despite condoning procedural delay, the Court emphasized the necessity of judicial sanction for such transfers and declined to interfere with the High Court’s application of the statutory provision.

Sections 241, 188 of the Companies Act, 2013 - NCLT Ahmedabad Orders Reversal of Slump Sale of ‘Tea Post’ Brand Due to Lack of Unanimous Approval and Transparency in Asset Valuation - Given the absence of a unanimous resolution and a credible valuation report, the NCLT, Ahmedabad Bench, has directed that the amount realized from the business transfer be reverted to Respondent No. 9. Moreover, it has mandated that Respondent No. 9 must retain an interest in Respondent No. 10, ensuring continued oversight and participation in the business. A new memorandum of agreement is to be executed, delineating the rights, obligations, and profit/loss sharing between the group company and the SPV. This decision highlights the necessity for procedural compliance, transparency, and protection of minority interests in intra-group business transfers.

Ahmedabad NCLT Sets Aside Fraudulent Share Transfer; Orders Removal of Director Over Oppression and Mismanagement - The NCLT’s decision unequivocally establishes that any transfer of shares executed without a proper transfer deed, valid consideration, and express consent of the shareholder is void ab initio. The Tribunal’s intervention under sections 241-242 is warranted where there is clear evidence of fabricated documents and fraudulent exclusion of shareholders from the management. Additionally, the Tribunal reaffirmed that limitation does not preclude relief where the petitioner discovers the wrongful acts only upon later inspection of official records.

Supreme Court Affirms Equitable Interpretation of “Member” in Oppression and Mismanagement Cases: Formal Register Entry Not Mandatory for Locus Standi - The Supreme Court has clarified that for the specific remedial purposes of Sections 397 and 398 of the Companies Act, 1956, an individual may be regarded as a “member” even in the absence of formal entry in the register of members, provided that his beneficial ownership and factual recognition by the company are established. This equitable approach ensures that minority shareholders are not unjustly deprived of remedies against oppression and mismanagement due to procedural lapses or technical omissions. The appeals against the respondent were dismissed, and the deposited amount with accrued interest was ordered to be released to him.

Sections 241, 167 of the Companies Act, 2013 - NCLT Ahmedabad Rules on Family Dispute in Company: Equal Control Achieved, Buyout Not Feasible Without Registered Family Settlement - In summary, the NCLT Ahmedabad Bench concluded that while procedural irregularities were present in the removal of directors and in the conduct of board meetings, the core dispute arose from a breakdown in the family’s business arrangement rather than legal oppression or mismanagement as defined under Section 241. The Tribunal refused to adjudicate on time-barred share transfer issues and found that, due to equal shareholding and joint land ownership, traditional remedies like a forced buyout were neither feasible nor executable. The actionable direction was to execute a comprehensive and registered family settlement within two years, following completion of audit requirements.

NCLAT Rules Against Exclusion of Limitation Period for Non-Bona Fide High Court Proceedings in Company Law Appeal - The NCLAT, Chennai, has categorically held that directions issued by the High Court regarding limitation cannot override specific statutory provisions under the Companies Act. Section 14 of the Limitation Act will not be available unless the prior proceedings were prosecuted with bona fide, due diligence, and good faith. In the absence of these, and in light of the self-contained limitation provision under Section 421(3) of the Companies Act, the delay condonation application was rightly rejected, and the appeal was dismissed as barred by limitation.

NCLAT Chennai Bars Re-litigation of Company Dispute; Res Judicata Invoked Against Repetitive Reliefs Sought on Same Cause of Action - The NCLAT’s ruling affirms that once a dispute has been conclusively resolved through appropriate legal channels, including the opportunity for appellate review, the parties are barred from raising the same issues in subsequent proceedings. Withdrawal of a pending appeal, absent any specific liberty granted by the court, does not diminish the finality of the prior adjudication. Consequently, the later company appeal was dismissed as barred by res judicata and as an abuse of process.

Sections 241, 242 of the Companies Act, 2013 - NCLT Ahmedabad Allows Conditional Operation of Company’s Fifth Bank Account Under Independent Oversight Amidst Shareholder Dispute - Based on the facts and legal provisions considered, the NCLT Ahmedabad Bench has conditionally permitted the operation of the company’s fifth bank account, strictly under the Independent Administrator’s supervision and subject to verification within the ongoing forensic audit. Payments to DWTS may be made only after due confirmation of liability. This interim relief is designed to protect the interests of all stakeholders and to ensure that no prejudicial activity occurs while the dispute remains sub judice.

Madras High Court Declares Writ Petition Not Maintainable Against CESTAT Orders: Directs Petitioner to Pursue Statutory Appeal Under Section 35G - In light of the above analysis, the Madras High Court has reaffirmed the principle that writ petitions challenging CESTAT orders are not maintainable when a statutory appellate remedy under Section 35G of the Central Excise Act, 1944 is available. Petitioners are required to exhaust the prescribed statutory remedies prior to seeking intervention under writ jurisdiction. The actionable takeaway is that litigants should carefully assess the availability of statutory remedies and pursue them as a matter of course, reserving writ petitions for exceptional circumstances only.

CESTAT Delhi Holds Consistent Classification Bars Reclassification of ‘MAMA Zarda’ as Zarda Scented Tobacco; Penalties Under Rule 26 Also Set Aside Absent Confiscation Finding - The CESTAT, New Delhi, decisively held that ‘MAMA zarda’ remained classifiable as chewing tobacco under CETI 2403 99 10, given the consistent classification by both the appellant and the Department for several years. As the Department could not validly reclassify the product and no basis for confiscation was established, all demands for differential duty, interest, and penalties, as well as penalties under Rule 26, were set aside.

CESTAT Chandigarh Bars Revenue from Reopening Cenvat Credit Deductions Post-Final Refund Order: Refund to Be Paid as Originally Quantified - The CESTAT Chandigarh decisively held that once a refund order (including the deduction of Cenvat credit) is sanctioned by the adjudicating authority and the department does not challenge the quantification, the refund amount attains finality. The department cannot, at the implementation stage or in proceedings limited to the issue of unjust enrichment, reopen or make further deductions from the refund amount. The appeals were allowed, restoring the refund quantum as originally sanctioned.

CESTAT Bangalore Overturns Penalty on Customs Broker for Alleged Regulatory Breach in Sugar Smuggling Attempt via Rice Export - The CESTAT, Bangalore, definitively ruled that penalties under the Customs Broker Licensing Regulations cannot be sustained in the absence of concrete evidence demonstrating that the Broker had knowledge of, or was complicit in, the exporter’s illegal activities, or had failed to fulfill due diligence and KYC obligations. Errors of a clerical or typographical nature, without more, do not amount to regulatory violations. The Customs Broker’s conduct was found to be in compliance with the regulatory framework, warranting the setting aside of the penalty.

CESTAT Bangalore Quashes Penalty on Customs Broker for Delay and Procedural Lapse in Issuance of Disciplinary Notice Under CBLR, 2018 - The Tribunal conclusively held that, although disciplinary action may be initiated on the basis of a show cause notice forwarded by another Commissionerate, such action must strictly comply with the mandatory ninety-day limitation and procedural requirements laid down in Regulation 17(1) of the CBLR, 2018. The failure to issue the notice within the prescribed period rendered the penalty order under Regulation 18 unsustainable, leading to its setting aside and allowing of the appeal by the Customs Broker.

CESTAT Allahabad Permits Provisional Release of Seized Gold on Furnishing Bond and Bank Guarantee—Gold Not Prohibited, Mere Allegations Insufficient for Denial - In conclusion, the Tribunal’s decision establishes that provisional release of gold and gold jewellery seized under Section 110A cannot be withheld merely on the basis of ongoing investigation or mere allegations of smuggling, especially where the goods are not prohibited and the person concerned is able to furnish reasonable evidence of licit procurement. The Department must release the goods upon execution of a bond for the full value and furnishing a bank guarantee for 50% of the value with an auto-renewal clause.

Delhi High Court Affirms: Import Restriction Notification Effective Only Post e-Gazette Publication—Retroactive Application to Prior Arrivals Barred - The Delhi High Court’s decision makes clear that import restriction notifications issued under delegated legislation become effective only upon their publication in the manner prescribed—here, the e-Official Gazette—and not before. Any attempt to retrospectively apply such notifications to goods that arrived prior to publication is legally unsustainable unless expressly empowered by the parent statute. Actionably, importers whose goods arrived in India before the official time of publication of such restrictions are entitled to have their consignments cleared under the previous legal regime.

No Lapsing of CENVAT Credit or 10%/5% Liability Where Separate Accounts Maintained and Exports Under Bond—Relief to Assessee on All Fronts - The CESTAT Delhi unequivocally upheld the adjudication order, dismissing departmental appeals and confirming that: (i) CENVAT credit did not lapse under Rule 11(3) where common inputs were used for both dutiable and exempt goods; (ii) no liability under Rule 6(3) arose in the absence of an exercised option and with proper maintenance of separate accounts; and (iii) Rule 6(3) did not apply to exempted goods exported under bond. This decision establishes that the department cannot enlarge the scope of demands beyond the show cause notice or ignore procedural and substantive requirements of the CENVAT Credit Rules.

CENVAT Credit Admissible on Mining, Handling, and Crushing Services in Captive Mines—Process Integral to Manufacture - Based on the Tribunal’s findings, manufacturers can legitimately avail CENVAT credit on the service tax paid for mining, handling, and crushing services in captive mines, even if a portion of ore is discarded during the process, so long as these activities are integrally connected to the manufacture of the final product. The impugned order denying such credit, along with interest and penalty, was thus set aside. Assessees should ensure that all such services are properly documented as being used in or in relation to manufacture to defend their credit claims.

CESTAT Mumbai Affirms CENVAT Credit on Re-Manufactured Machinery Cleared to New Buyer; Rebukes Adjudication Beyond Show Cause Notice - In light of the above, the CESTAT Mumbai categorically allowed the appeal, affirming that CENVAT credit is admissible under Rule 16 on duty-paid goods returned to the factory, even if the resultant product is a new machine manufactured using parts of the old machinery, and is cleared to a different buyer on payment of duty. The order of the Commissioner (Appeals) denying credit on grounds not mentioned in the show cause notice was held to be legally untenable and was set aside, with consequential relief for refund and interest as per law.

Supreme Court Declines Interference in Depot-Based Valuation Notice; Allows Fresh Challenge Against Subsequent Order - The Supreme Court’s refusal to interfere with the High Court’s order effectively upholds the validity of show-cause notices issued under Section 11A on grounds of suppression, where supported by prima facie evidence. However, parties retain the right to contest any adverse order-in-original, ensuring that their substantive rights are not foreclosed at the notice stage. Assessees facing similar show-cause notices must prepare to challenge the factual basis of suppression in subsequent adjudication proceedings.

Delhi High Court Rules Import Restriction Notification Prospective: Goods Arrived Before E-Gazette Publication Not Liable to New Restrictions - The Delhi High Court decisively held that Notification No. 02/2026-27, altering the import policy for CTH 7113 goods from “Free” to “Restricted”, became legally effective only upon its publication in the e-Official Gazette at 20:52:28 hrs on 2nd April 2026. Goods that arrived in India prior to this timestamp were not subject to the new restrictions, and customs authorities are obligated to process their release under the earlier policy framework. This conclusion is actionable: importers whose goods arrived before the publication timestamp are entitled to clearance under the erstwhile regime regardless of the subsequent policy change.

CESTAT Upholds Penalty for Deliberate Ketamine Export Under False Declaration; Redemption Fine Quashed Due to Non-availability of Goods - The CESTAT's decision conclusively establishes that deliberate misdeclaration of controlled substances for export using fabricated documents and fraudulent schemes attracts strict penal consequences under Customs law. However, redemption fine cannot be imposed if the goods are not physically available for confiscation at the time of adjudication and were not exported under any bond. Appellants in similar circumstances should ensure that any defense based solely on their limited role must be substantiated by clear evidence, as mere denial is insufficient in the face of corroborative circumstantial and testimonial evidence.

CESTAT Quashes Duty Demand and Penalties on SEZ Jewellery Unit; Holds Acceptance of Amended Bond Valid and Discards Unsupported Allegations of Diversion and Non-Manufacture - In summary, the CESTAT decisively set aside the Commissioner’s order, holding that Bharti Gems had not exceeded its procurement limit under the properly accepted Bond-cum-Legal Undertaking, and that the department’s reliance on unsupported statements and data was misplaced. All demands, confiscations, and penalties arising out of these proceedings were quashed, and the appeals were allowed in favor of the assessee.

CESTAT Allahabad Nullifies Confiscation of Gold in Town Seizure: Statutory Presumptions Not Attracted in Absence of Cogent Proof and Procedural Lapses - On a careful assessment of both substantive and procedural legal requirements, CESTAT Allahabad concluded that the Customs Department failed to establish the foreign origin or smuggled nature of the gold in a town seizure, especially in the absence of foreign markings, direct evidence, and compliance with Section 138B of the Customs Act. Consequently, the Tribunal upheld the order of the Commissioner (Appeals) and dismissed all appeals filed by the Department. This decision underscores that statutory presumptions in customs law cannot be invoked lightly in town seizures; strict adherence to evidentiary and procedural requirements is mandatory.

CESTAT Allahabad Quashes Penalty under Section 112(b) for Alleged Smuggled Gold: Insufficient Proof of Foreign Origin and Conscious Knowledge - The decision of CESTAT Allahabad conclusively establishes that, in cases of town seizure, mere suspicion or inconclusive technical evidence such as gold purity reports below recognized thresholds cannot justify penalties under Section 112(b) of the Customs Act, 1962. The Department must unambiguously demonstrate the foreign origin, illicit importation, and conscious knowledge on the part of the accused. Absent such proof, penalties are liable to be quashed, and relief should be granted to the appellants.

No Penalty Under Section 112(a) Where Imported Goods Not Liable to Confiscation, Departmental Appeals Dismissed - In summary, the Tribunal affirmed that penalty proceedings under section 112(a) of the Customs Act cannot be sustained unless the imported goods are found to be liable to confiscation under section 111. Since the adjudicating authority had already recorded a categorical finding negating such liability, the penalty proceedings were rightly dropped. The Tribunal saw no legal infirmity in the adjudicating authority’s order and dismissed all departmental appeals.

CESTAT Bangalore Quashes Denial of CENVAT Credit on Input Services: Extended Limitation Period and Penalties Also Set Aside Due to Lack of Suppression - In summary, the CESTAT Bangalore set aside the impugned order, allowing the appellant’s appeal in full. The decision confirms that denial of CENVAT credit on the disputed input services was unjustified, the extended period of limitation was wrongly invoked in the absence of suppression, and the consequential interest and penalty were not sustainable.

CESTAT New Delhi Upholds CENVAT Credit on Insurance, Works Contract, and Manpower Services Despite Invoice Lapses: Scope of Input Services Clarified - Based on the Tribunal’s findings, the assessee was deemed eligible for CENVAT credit on marine cargo insurance, works contract for repair and maintenance, and manpower supply services. The Tribunal further established that procedural defects in invoices do not bar credit entitlement if substantive conditions are met. The assessee's appeal was allowed, the disallowance of credit was set aside, and the department's appeal regarding manpower supply services credit was dismissed. Taxpayers should ensure substantive compliance while not being unduly penalized for minor procedural lapses.

CESTAT Bangalore Upholds Importer’s Classification of Airspan Air Velocity 2700 as Synchronous Digital Hierarchy System under Customs Tariff Heading 8517 6260 - In dismissing the Revenue’s appeal, the CESTAT, Bangalore has conclusively held that the Airspan Air Velocity 2700 is appropriately classified under Customs Tariff Heading 8517 6260. The Tribunal’s decision underscores the primacy of a functional test in determining the classification of telecom equipment and affirms that the importer’s declaration, when substantiated by technical evidence, will be upheld. Importers should ensure that product documentation and technical specifications clearly substantiate the functional use claimed for tariff classification purposes.

Interest and Penalty Unwarranted Where EPCG Export Obligation Frustrated by Force Majeure—Confiscation Set Aside Following Auction of Capital Goods - In summary, the CESTAT Delhi has re-affirmed that where an assessee’s inability to fulfil EPCG export obligations is due to circumstances genuinely beyond their control (force majeure), neither interest nor penalty nor confiscation of goods can be legally sustained once bank guarantees have been encashed and no mala fide intent is established. The customs duty demand, however, stands if not specifically contested.

CESTAT Mumbai Affirms Edible Grade Status Sufficient for Customs Exemption: CBEC Circular Cannot Impose Additional End-Use Conditions on Imported Refined Oils - The decision of the CESTAT Mumbai establishes that where an exemption notification under customs law prescribes only objective criteria—such as tariff classification and edible grade—the authorities cannot deny exemption by imposing additional end-use conditions through administrative circulars. Documentary and laboratory evidence demonstrating compliance with the specified grade is sufficient to claim the benefit. Importers should ensure that their goods meet the edible grade standard as certified by recognized laboratories to avail exemption under similar notifications, irrespective of the declared end-use.

Customs Tribunal Quashes Penalty on Broker: No Abetment When Importer Exonerated in Classification Dispute - In summary, the CESTAT Chennai’s decision unequivocally holds that where an importer is exonerated on grounds of bona fide interpretational dispute in classification, the Customs Broker, acting solely on the importer’s instructions, cannot be penalized for abetment or for making a false declaration under Sections 112(a) and 114AA. The order directs deletion of all penalties imposed on the Brokers in such circumstances.

CESTAT Chennai Rules Exclusion of Exported Exempted Goods’ Value from CENVAT Credit Reversal under Rule 6(3A): Relief Granted in Cotton Yarn Export Case - In light of binding precedent and the absence of any contrary authority or distinguishing facts, the CESTAT Chennai held that the value of cotton yarn exported without payment of duty under the DEPB scheme should be excluded from the computation of exempted clearances under Rule 6(3A) of the CENVAT Credit Rules, 2004. The appeal was allowed, and the impugned order was set aside, with consequential relief to the appellant.

Extended Limitation and Rule 26 Penalty Set Aside Where Department Had Prior Knowledge and No SCN Proposal - The CESTAT Chennai set aside the impugned order, holding that the extended period of limitation had been wrongly invoked as the Department had prior knowledge of all material facts, and that the penalty under Rule 26 could not be sustained in the absence of any proposal in the show cause notice or any reasoned order. The appeal was accordingly allowed, with all consequential benefits as per law.

CESTAT Chennai Rules Against Customs in EPCG Third-Party Export Dispute: EODCs and EPCG Benefits Restored; Penalties and Confiscation Set Aside - In light of the above, the Tribunal decisively concluded that Customs authorities are not empowered to disregard EODCs restored by the DGFT, especially in the absence of substantive evidence of fraud or conscious wrongdoing. The denial of EPCG benefits, demands for differential duty, confiscation of capital goods, and all penalties imposed were set aside in toto for all appellants. The Tribunal’s order provides actionable guidance: where the competent DGFT authority has restored EODCs after considering all relevant objections and policy clarifications, Customs must accept such determinations as final and binding unless there is fresh, conclusive evidence of fraud or misrepresentation.

CESTAT Chennai Affirms Substantial Compliance: Refund Cannot Be Denied for Mere Formal Defects in Chartered Accountant Certificate - On the basis of the Tribunal’s decision, it is actionable that refund claims under the Central Excise Act, 1944, must be adjudicated on the merits of the claim rather than on technical lapses in documentation, particularly when such lapses are only formal and do not affect the substance of the claim. Assessees should ensure that all material particulars supporting the claim are provided, but minor deviations from prescribed formats—especially where the intent and substance are clear—cannot be grounds for denial.

CESTAT Chennai Quashes Customs Demand: Declared Value of Imported Apples Upheld Due to Lack of Cogent Evidence; Penalties and Confiscation Set Aside - The Tribunal, upon meticulous examination of the evidence and legal provisions, set aside the order of the lower authority. It held that the Department failed to adduce legally admissible and corroborated evidence to displace the declared transaction value or prove undervaluation. As a result, all consequential actions—redetermination of value, demand for differential duty, confiscation, and penalties—were found unsustainable. The appeals were allowed in full, with consequential relief to the appellants.

CESTAT Chennai Upholds Reclassification of AKD Wax as Prepared Waxes under CTH 3404; Restricts Duty Demand to Normal Period and Sets Aside Penalties and Past Confiscations - The CESTAT Chennai conclusively held that Alkyl Ketene Dimer (AKD Wax) is properly classifiable as a prepared wax under CTH 34049090, not as a chemically defined organic compound under Chapter 29. The Tribunal restricted the demand for differential customs duty to the normal period as per Section 28(1) of the Customs Act, 1962, with interest, and set aside demands for the extended period, as the facts were always within the Department’s knowledge. Confiscation was sustained only for the live consignment, with redemption fine imposed thereon, while confiscation of previously cleared goods and all penalties on the importer, its officers, and Customs House Agent were quashed. Importers in similar factual contexts should ensure consistent and transparent declarations while relying on HSN and technical analysis for classification.

Supreme Court Declines to Interfere in Excise Rule 8(3A) Appeal Due to Low Tax Effect; Constitutional Validity Issue Remains Open - The Supreme Court’s summary dismissal of the Department’s SLP, following the High Court’s disposal of the appeal on the grounds of low tax effect and departmental litigation policy, means that the core issue of the constitutional validity of Rule 8(3A) remains unresolved. Both the High Court and Supreme Court have left the door open for this substantial legal question to be considered in future proceedings, should a case arise with a higher tax impact or not barred by policy thresholds.

Guidelines for Compulsory Selection of returns for Complete Scrutiny during the Financial Year 2026-27

Central Government Notify the Specified business for the purposes of Schedule V [Table: Sl. No. 7] of the Income Tax Act, 2025

Approval under Section 45(4)(b) of the Income Tax Act, 2025 for 'Ramakrishna Mission Vidyamandira' Howrah

Approval under Section 45(4)(b) of the Income Tax Act, 2025 for "Regional Centre for Biotechnology, Faridabad, Haryana"

Approval under Section 45(4)(b) of the Income Tax Act, 2025 for "S. Nijalingappa Sugar Institute, Belgaum"

Health Security se National Security Cess (Second Amendment) Rules, 2026.
Dress Code for Authorised Representatives Appearing before the GST Appellate Tribunal
Goods & Services Tax Appellate Tribunal - Constitutes Benches and Categorises GST Appeals
Extension of Guidelines and Instructions for Scrutiny of Appeals Filed on GSTAT Portal
Seeks to amend Notification No. 14/2018-Union territory Tax, vide G.S.R. 1004 (E), dated the 8th October 2018
Seeks to bring in force provisions of relating to the Copyright Act, 1957- Jan Vishwas (Amendment of Provisions) Act, 2026
Seeks to bring in force provisions of Patents Act, 1970 - Jan Vishwas (Amendment of Provisions) Act, 2026
Seeks to bring in force provisions of Works of Defence Act, 1903 - Jan Vishwas (Amendment of Provisions) Act, 2026
Seeks to bring in force provisions of Indian Succession Act, 1925 and the Administrators-General Act, 1963 - Jan Vishwas (Amendment of Provisions) Act, 2026
Master Circular on Surveillance of Securities Market
Fixation of Tariff Value of Edible Oils, Brass Scrap, Areca Nut, Gold and Silver
Notification under Section 28A of Customs Act,1962 for non levy of customs duty on import of goods for generation of nuclear power, falling under tariff items 84013000
Amendment in Notification No. 51/2021-Customs(ADD), dated the 16th September, 2021
Amendment in Notification No. 4/2021-Customs (CVD), dated the 24th September, 2021
Seeks to amend Notification No. 11/2017-Central Excise, dated the 30th June, 2017
Amendment in Notification No. 28/2002-Central Excise, dated the 13th May, 2002
Central Government exempts the excisable goods
Seeks to amend Notification No. 3/2021-Central Excise, dated the 1st February, 2021
Introduction of system-based e-Scheduling for examination of cargo
Notification of access road area of 1,18,089.89 square meters of M/s BMCTPL as Customs Area

Most Read

Article - The Cross Charge vs. ISD Dilemma Under GST for Multi-State Organisations
Article - Unraveling the Cannabis vs. Ganja Dilemma: Understanding Botanical and Legal Complexities under the NDPS Act
Article - Artificial Intelligence and Taxation: Re-examining the Legal Framework for Assessing Value Creation
Article - Agreement for Sale under RERA, 2016: Structure, Essential Clauses, and Legal Consequences
Article - Imposition of Penalty on Company and Directors for Non-Cash Dealings Without Shareholder Consent: An Analysis
Article - How ROC Adjudication Orders Are Transforming Compliance in Corporate Fundraising
Article - Reassessment Notices Issued to Deceased Assessees: Conflicting Approaches in Recent Delhi High Court Rulings on Section 148A
Article - Charitable and Religious Trusts: Interpreting Section 13(1)(b) in Light of the Jamia Osman Bin Affan Education Society Case
Article - GST Implications on 'Buy One Get One' (BOGO) Offers: Free Units, Credit Notes, and Proper Adjustment Strategies
Article - GST and Online Gaming in India: Supreme Court’s New Framework and Its Implications
Article - GST Implications on Corporate Guarantees: Analysis of Bombay High Court’s Position on Absence of Consideration
Article - Transitioning to the Income-tax Act, 2025: New Challenges for Professionals in Bookkeeping and Compliance
Article - Representation by Authorised Representative in Income Tax Proceedings: A Detailed Overview
Article - Indirect Transfers under Indian Income Tax Law
Article - Analysis of Sections 14 and 171 of the CGST Act in the Context of Battery Operated Vehicle Procurement: Insights from the CAG Compliance Audit Report
Article - Private Discretionary Trusts and Section 56(2)(x) – Interpreting ‘Solely for the Benefit of Relatives’
Article - Section 153C Satisfaction Note: The Foundational Jurisdictional Principle and Its Persistent Defects
Article - The Role of Adjudication in Indian Tax Tribunals
Article - Section 107 and the Prohibition of Remand: No Second Chances for the Department under GST
Article - Mastering GST Scrutiny: Strategic Handling of Form GST ASMT-10 to Prevent Litigation
Article - Directors’ Responsibility Statement (DRS) under Section 134(5): The Need for a Structured Board Assurance Protocol
Article - Elevated Status of Compliance Officer and Company Secretary: Accountability in Cases of Non-Compliance
Article - Section 50CA and Bona Fide Transfers of Unquoted Shares: Applicability and Interpretation
Article - Distinguishing Revenue Sharing and Profit Sharing in AOPs: Taxability of Members’ Income in Light of Sanand Properties Case
Article - GST Implications on Corporate Guarantees: Key Developments and Practical Guidance after D.P. Jain & Co. Infrastructure Pvt. Ltd. v. Union of India
Article - GST on Online Gaming in India: A Comprehensive Legal and Economic Overhaul
Article - Implications of Backdated Whole-Time Director Appointments: Lessons from ROC Penalty on M/s. Regaal Resources Limited
Article - SEBI to Reintroduce Open Market Buy-Backs via Stock Exchange: A Shift in Buy-Back Regulations
Article - Taxation of Hoarding Income – Standard Deduction Eligibility
Article - Comprehensive Overview of the Regulatory Regime for Virtual Power Purchase Agreements (VPPAs) in India
Page 1 of 10 (300 items)Prev[1]2345678910Next

Top Categories

Commentary

Always updated Income Tax Commentary

Direct Taxes

Decisions, Acts, Rules, Circulars, Finance Acts/Bills, Ready Reckoner, Digests, Books, Search

Service Tax

Decisions, Acts, Rules, Digests, Circulars, Practice Updates, Landmark Decisions, Search

Corporate Laws

Decisions, Acts, Rules, Regulations, Circulars, Procedurs, SEBI, Securities Laws, Search

Company Law Ready Reckoner, 2015

Procedures, Resolutions, Formats, Compliance, Check Lists, Main Objects, Circulars, Articles

FEMA/RBI

Decisions (FEMA and DRT Cases), RBI Circulars, FEMA Rules and Regulations, FDI

Indian Acts

Direct, Indirect, Corporate, Securities, Economic, Labour, Industrial, Insurance, Forex Laws

Deeds & Documentation

Deeds & documentation (Partnership, HUF, Gift, POA and 45 other categories covering around 1,500 deeds annd agreements. Editable.

GST

Tarrif/Non Tariff Notification, Circulars, SC/HC/CESTAT Cases, Acts, Rules, Regulations

Excise

Tarrif/Non Tariff Notification, Circulars, SC/HC/CESTAT Cases, Acts, Rules, Regulations

Customs

Tarrif/Non Tariff Notification, Circulars, SC/HC/CESTAT Cases, Acts, Rules, Regulations

VAT

STC (All Volumes), VST, VST-OL, TaxCorp (VAT) Decisions, All India VAT Circulars, Notifications

Accounting/Auditing

Accounting Policy, AS, AAS, IndAS, Opinions, Guidance Notes, Company Audit

Annual Reports

Annual Reports (IndAS and IFRS based), Segment-wise, Company-wise

Indian Rules

Direct, Indirect, Corporate, Securities, Economic, Labour, Industrial, Insurance, Forex Laws

TaxCorp Forms

Income Tax, Service Tax, Excise, Customs, FTP, FEMA & SEZ. Editable.

TaxCorp Search

Premium Search Enginge with intelligence built in. Guaranteed to give results within top 5 search results.

Top Tax Stories

Realtime coverage of Direct, Indirect and International Taxation. All important judgments not to be missed.

TaxCorp International Taxation

Comprehensive and exhaustive resource on International Taxation, Transfer Pricing, Double Taxation Tax Treaties, FDI, FEMA, BIPA, NRI. All Indian Transfer Pricing cases as well as News

TaxCorp intelligent Search Tool developed exclusively for International Taxation and Transfer Pricing Module. Search DTAA Article-wise case laws, Country-wise, topical search. Analysis of important international judgments on Transfer Pricing. Expert columns and Articles related to TP

🚀 Welcome to TaxCorp 2.0!
India's First AI-Powered Tax Platform is Now Live!

✨ AI Tax Assistant - Get instant answers
📄 Smart Document Analysis - Upload & analyze
🔍 Intelligent Search - AI-enhanced results
📱 Mobile Optimized - Works on all devices

Your existing login will work on the new platform!