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Archive: February, 2026

Posts in February, 2026

Engine Oil Cooler Classifiable as Heat Exchange Unit Due to Specific Functional Design: CAAR Mumbai

February 7, 2026 249 Views 0 comment Print

Applying the General Rules of Interpretation, the Authority preferred the precise heat exchanger entry over the general vehicle parts heading. The decision reinforces the primacy of specific tariff descriptions.

Washing Machine Use Not Enough to Classify Ceramic Resonator as Appliance Part: CAAR Mumbai

February 7, 2026 315 Views 0 comment Print

The Authority examined whether a ceramic resonator used in appliance control boards could be treated as a machine part. It held that specific coverage under Heading 8541 prevails, classifying the product as a mounted piezoelectric crystal.

Controlled Cant Benchmark Controlled – Pro-Rata Commission TP Struck Down

February 7, 2026 201 Views 0 comment Print

The authorities compared intra-group commission rates without economic analysis. The Tribunal ruled that such an approach leads to invalid transfer pricing adjustments.

WhatsApp Chats ≠ Unexplained Money – U/s 69A & 115BBE Crumble Without Cash or Ownership

February 7, 2026 561 Views 0 comment Print

The Tribunal ruled that Section 69A applies only when the assessee is found to be the owner of money or assets. Mere suspicion or digital communication cannot replace proof of possession or ownership.

Fraudulent ITC & Fake Invoices under GST: Applicability of Sections 73, 74, 122 & 132

February 7, 2026 2712 Views 0 comment Print

This case explains situations where ITC is availed and utilised without receipt of goods or services. The ruling clarifies that such ITC is recoverable with interest and penalty under Section 74.

Section 153C Valid, Bogus Purchases Fully Taxable Section 153D Approval Upheld – Assessee Loses on All Fronts

February 7, 2026 495 Views 0 comment Print

The issue was whether purchases recorded by the assessee were genuine. The Tribunal held that seized Tally data and statements proved bogus purchases, justifying full addition.

For Non-Searched Persons, Clock Starts on Receipt of Books – Revenue’s U/s 153C Theory Rejected

February 7, 2026 207 Views 0 comment Print

The ITAT ruled that limitation begins when seized material is handed over to the assessing officer of the non-searched person. The key takeaway is that procedural safeguards apply even in search-related cases.

Cherry-Picked Comparables Rejected Assessees Set Ignored – TP Matter Sent Back for Fresh Benchmarking

February 7, 2026 288 Views 0 comment Print

The Tribunal found that lower authorities failed to follow binding coordinate bench decisions on comparability. The case was sent back for re-determination in accordance with law.

Indo–American Trade Deal – All’s Well That Ends Well

February 7, 2026 408 Views 0 comment Print

After months of tense negotiations, tariffs on Indian goods were cut to 18%. The decision underscores the value of diplomacy over coercion in resolving trade disputes.

Opening Balance Can’t Be Taxed Again & Corpus Fails Only Where Proof Fails – Revenue Routed

February 7, 2026 195 Views 0 comment Print

The ITAT ruled that accumulated building funds carried forward from previous years are not taxable in the year under scrutiny. The decision reinforces that taxation must align strictly with the year of receipt.

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