The Bill decriminalises minor offences by converting them into civil penalties, reducing fear of prosecution for procedural lapses. This approach encourages compliance while maintaining deterrence through financial penalties.
The law granting special powers to armed forces was upheld, but courts emphasized that such powers are not absolute. Safeguards like proportional use of force and timely handover of detainees were mandated.
The new tax law addresses long-standing concerns over complexity by reducing provisions and simplifying language. It introduces structural clarity and digital tools to improve compliance while reducing taxpayer burden.
The Supreme Court affirmed that payments for cloud computing services are not royalty where no intellectual property rights are transferred. It held that mere access to services does not amount to use of equipment or technology under tax law.
The Court held that the issue of treating DRP upload as receipt was already settled by earlier rulings. It dismissed the Revenue’s appeals while making the decision subject to the Supreme Court’s final outcome.
The Tribunal held that trading and service activities were inextricably linked and could not be segmented. It accepted entity-level TNMM, rendering TP adjustments unsustainable.
The Tribunal held that TDS credit cannot be denied merely because it does not appear under the assessee’s PAN. It ruled that the assessee cannot be forced to ensure revision of TDS returns by the deductor.
The Tribunal set aside the dismissal of a delayed appeal, holding that the issue of distribution fee taxability requires fresh examination on merits. The case was remanded to the Assessing Officer for reconsideration with proper hearing.
The Tribunal held that return of advances cannot be taxed under Section 68. The key takeaway is that explained transactions supported by records cannot be treated as unexplained income.
The Tribunal held that delay in filing the return due to pending probate proceedings was beyond the control of executors. It ruled that such delay constituted a bona fide explanation, leading to deletion of penalty under Section 270A.
