Author: inavatiq

Consultation Paper Dated 12.03.2026

The Securities and Exchange Board of India (SEBI) has issued a consultation paper proposing simplification of documentation requirements for transmission of securities and revision of threshold limits for simplified claims. The proposal also introduces a straight-through processing mechanism for low-value claims and seeks to standardise documentation and procedures across intermediaries to reduce delays and hardships faced by claimants.

The existing limits for simplified documentation are proposed to be revised from Rs. 5 lakh to Rs. 10 lakh for securities held in physical mode and from Rs. 15 lakh to Rs. 30 lakh for securities held in dematerialised form. In addition, SEBI has proposed the introduction of straight-through processing for very small claims, with minimal documentation requirements, up to Rs. 10,000 for physical securities and Rs. 30,000 for demat holdings.

The proposed framework will apply to listed companies, registrars and transfer agents (RTAs), depositories, depository participants (DPs) and asset management companies (AMCs) in relation to transmission of securities.

Where securities are held with a registered nomination, the nominee shall be informed about the procedure to be followed for making a claim upon receipt of intimation of the death of the security holder. In such cases, the following documents are required to be submitted:

a) Transmission request form submitted by the nominee

b) Latest Client Master List (CML) of the demat account, not older than two months and attested by the Depository Participant

c) Verifiable death certificate

d) Officially valid ID proof of the nominee

The consultation paper also proposes standardisation of the procedure for submission and processing of transmission claims. In this regard, entities will be required to adopt standardised formats for claim forms and documentation in consultation with the Industry Standards Forum for RTAs. Such forms shall be made available to claimants both in physical mode and on the websites of the respective entities along with details of the documents required and the applicable procedure.

Entities shall acknowledge receipt of the claim once the documents are submitted and, at the time of such acknowledgement, inform the claimant of any pending, missing, incomplete or incorrect documents. Upon submission of all required documents, the entity shall issue a confirmation that the claim is complete and will be processed.

Entities may also provide an online facility for submission of claims and tracking of claim status. Transmission requests are proposed to be processed within 21 calendar days from the date of receipt of all required documents.

Public comments on the consultation paper have been invited until April 2, 2026.

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Taxmann presents Practical Insights on Ind AS and SAs, a weekly series exclusively for Accounts and Audit Module subscribers of Taxmann.com, focusing on the practical application of Ind AS and Standards on Auditing through structured, issue-based analysis.

Each week features a focused topic with real-world illustrations. This edition discusses the roadmap for applicability of Ind AS to insurance companies in India, including regulatory developments, global accounting reforms in the insurance sector, proposed implementation timelines, and the expected impact of Ind AS adoption on the insurance industry.

1. Introduction

Indian Accounting Standards (Ind AS) represent India’s convergence with the global financial reporting framework under the International Financial Reporting Standards (IFRS). The objective of adopting Ind AS is to improve the transparency, comparability, and reliability of financial reporting across corporate entities.

While Ind AS has already been adopted by many Indian companies, the insurance sector has continued to follow a separate regulatory accounting framework due to the complex nature of insurance contracts, actuarial valuation requirements, and the need for prudential regulatory oversight.

Recognising the importance of aligning Indian insurance accounting practices with global standards, the Insurance Regulatory and Development Authority of India (IRDAI) has initiated a roadmap for implementing Ind AS in the insurance sector.

2. Existing Financial Reporting Framework and Proposed Transition to Ind AS

At present, insurance companies in India prepare their financial statements in accordance with the regulatory framework prescribed under the Insurance Act, 1938, the Companies Act, 2013, and the regulations issued by the Insurance Regulatory and Development Authority of India (IRDAI). These regulations prescribe detailed requirements relating to:

• Formats for financial statements
• Actuarial valuation of insurance liabilities
• Solvency reporting requirements
• Regulatory filings and disclosures
• Investment valuation norms

While this framework has provided a stable and prudential basis for financial reporting and regulatory supervision, particularly for safeguarding policyholder interests, it differs from the Ind AS framework in several areas such as the measurement of insurance liabilities, profit recognition, impairment of financial assets, and disclosure requirements.

In the context of increasing global convergence in financial reporting, the adoption of Ind AS 109, Financial Instruments and Ind AS 117, Insurance Contracts, aligned with the international standard IFRS 17, is expected to significantly improve the financial reporting framework for insurers. Transition to Ind AS would enhance global comparability, introduce market-consistent measurement of liabilities, improve performance disclosures, and strengthen governance and risk management practices. It would also support greater investor confidence and facilitate wider participation of Indian insurers in global capital markets.

3. Regulatory Developments and Initial Roadmap for Ind AS Implementation in the Insurance Sector

The Insurance Regulatory and Development Authority of India constituted an Implementation Group for Ind AS in the Insurance Sector through notification IRDA/F&A/ORD/ACTS/201/11/2015 dated 17 November 2015. The group submitted its report on 29 December 2016, which included a draft regulatory framework for implementing Ind AS in the insurance sector.

Subsequently, IRDAI notified the adoption of Ind AS for insurance companies for the accounting period 2020–21 through Circular IRDA/F&A/CIR/ACTS/146/06/2017 dated 28 June 2017, in line with the roadmap issued by the Ministry of Corporate Affairs for the adoption of Ind AS by insurance companies beginning 1 April 2018.

As part of the preparatory process, insurers were required to:

• Submit proforma Ind AS financial statements to IRDAI on a quarterly basis starting from December 2016, and
• Implement Ind AS 104 – Insurance Contracts from April 2018.

These requirements were intended to help regulators assess the potential impact of Ind AS adoption on the financial reporting of insurance companies.

4. Withdrawal of the earlier Ind AS roadmap and deferment of implementation in the Insurance Sector

The initial roadmap for mandatory Ind AS implementation was later reconsidered. Through Circular IRDA/F&A/CIR/ACTS/023/01/2020, the Insurance Regulatory and Development Authority of India withdrew the earlier circular issued in 2017, which had mandated the adoption of Ind AS from the financial year 2020–21. Along with this, the requirement for insurers to submit proforma Ind AS-based financial statements was also withdrawn. As a result, the adoption of Ind AS in the insurance sector was deferred until further notice.

Instead, it was decided that Ind AS 109, Financial Instruments and IFRS 17 (Ind AS 117), Insurance Contracts should be implemented simultaneously at a later stage to ensure consistency in financial reporting.

The deferment was primarily due to concerns regarding valuation inconsistencies under the existing framework. If Ind AS had been implemented in its earlier form, financial assets would have been measured at fair value or market value, while insurance liabilities would have continued to be measured using the existing formula-based actuarial approach. This difference in measurement bases could have resulted in a mismatch between asset and liability valuations, potentially leading to significant volatility in the financial statements of insurance companies.

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1. Introduction

The Corporate Laws & Corporate Governance Committee of the Institute of Chartered Accountants of India (ICAI) has issued the Handbook on Key Compliances and Exemptions for Private Limited Companies under the Companies Act, 2013,to provide a consolidated, practical reference on the regulatory framework applicable to private companies. The handbook brings together the various statutory provisions, exemptions, and procedural requirements in a structured manner, so that professionals, directors, and compliance officers can easily understand and implement the compliance requirements applicable to private limited companies.

2. Overview of the Handbook

Private limited companies constitute the most significant segment of the Indian corporate sector. A private company, as defined under the Companies Act, 2013, restricts the transferability of its shares, limits the number of members to two hundred and prohibits any invitation to the public to subscribe to its securities. These features ensure that ownership remains closely held while providing the benefits of limited liability and a structured corporate framework. The handbook also highlights that private companies represent the majority of active companies in India, demonstrating their importance in promoting entrepreneurship and business growth.

The handbook discusses the procedural framework for the incorporation of private companies, which is carried out through the SPICe+ system on the MCA portal. The process involves reservation of the company name, filing incorporation documents such as the Memorandum of Association and Articles of Association, submission of declarations by subscribers and directors, and certification by a practising professional.

A significant portion of the handbook focuses on the exemptions and relaxations available to private companies under the Companies Act, 2013. Since private companies operate with a limited number of stakeholders and do not raise funds from the public, the Central Government has granted various exemptions through notifications issued under the Act. These exemptions modify the applicability of certain provisions relating to governance and procedural requirements, thereby reducing compliance burdens while maintaining essential standards of corporate governance.

The handbook also outlines key statutory compliances applicable to private companies. These include event-based compliances such as changes in registered office, alteration of memorandum or articles of association and issuance of securities through mechanisms such as private placement, rights issue or bonus issue.

Further, the handbook highlights the consequences of non-compliance with statutory requirements. Delays in filing annual returns, failure to maintain statutory registers or non-compliance with other provisions of the Companies Act may attract penalties for both the company and its officers. These provisions emphasise the importance of timely compliance and proper corporate governance practices.

3. Conclusion

Overall, the handbook serves as a comprehensive guide that consolidates the legal provisions, exemptions and compliance requirements applicable to private limited companies under the Companies Act, 2013. By presenting these requirements in a structured and practical manner, it assists professionals and stakeholders in understanding and navigating the regulatory framework governing private companies in India.

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CORRIGENDUM No. SEBI/LAD-NRO/GN/2026/297 dated 10.03.2026

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Case Details: Indian Medical Association vs. Deputy Commissioner of Income-tax, Exemption - [2026] 183 taxmann.com 735 (Pune-Trib.)

Judiciary and Counsel Details

• R. K. Panda, Vice President & Ms Astha Chandra, Judicial Member
• Nikhil S Pathak for the Appellant.
• Vidya Ratna Kishore for the Respondent.

Facts of the Case

The assessee was a public charitable trust formed under the Bombay Public Trust Act, 1950. It filed its updated return of income under section 139(8A) after offering short-term capital gain and long-term capital gain and claiming exemption under section 11.

During the assessment proceedings, the Assessing Officer (AO) denied the assessee’s exemption claim. The AO considered that the Income Tax Act, as amended by the Finance Act, 2017, makes it mandatory for charitable and religious trusts to file their return of income within the due date specified under section 139(1) to claim exemption under section 11.

Thus, the exemption cannot be claimed in an updated return if no original return is filed. Aggrieved by the order, the assessee preferred an appeal to the CIT(A). The CIT(A) confirmed the order of the AO, and the matter then reached the Pune Tribunal.

ITAT Held

The Tribunal held that the relevant portion of the Memorandum explaining the Finance Bill, 2023, states that the exemption under section 11 will be available only if the return of income is furnished within the time allowed under section 139(1) or section 139(4). The amendment was introduced to exclude returns filed under section 139(8A). It was also submitted that, subsequent to the amendment brought in with effect from the assessment year 2023-24, no exemption under section 11 would be allowable when the same has been claimed in an updated return under section 139(8A).

Therefore, before the assessment year 2023-24, even if the same has been claimed in an updated return under section 139(8A), the exemption under section 11 cannot be denied. Accordingly, the assessee cannot be denied the exemption under section 11 on account of filing the updated return.

List of Cases Reviewed

• Dy. CIT v. Bishnupur Public Education Institute [2025] 172 taxmann.com 307 (Kol-Trib) (para 16) followed

List of Cases Referred to

• Dy. CIT v. Bishnupur Public Education Institute [2025] 172 taxmann.com 307 (Kol-Trib) (para 10).

The post Section 11 Exemption Allowed in Updated Return for Pre-AY 2023-24 | ITAT appeared first on Taxmann Blog.

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Case Details: Indian Institute of Management, In re - [2026] 184 taxmann.com 46 (AAR-GUJARAT)

Judiciary and Counsel Details

• Sushma Vora & Vishal Malani, Member
• Paritosh Gupta, Adv. Patel Mit Dineshbhai, Asstt. Commissioner for the Applicant.

Facts of the Case

The applicant, an educational institution, registered under GST sought an advance ruling regarding its obligation to deduct Tax Deduction at Source (TDS). It submitted that Section 51 of the CGST Act mandates deduction of tax at source at the rate of 1% where the value of supply under a contract exceeds ₹2.5 lakh. The applicant was seeking clarification regarding the computation of the ₹2.5 lakh threshold for TDS, particularly whether the threshold should apply per contract excluding GST, whether multiple invoices under a single contract would affect the threshold, and how the threshold should be determined where separate contracts with the same supplier or continuous supplies exist. The matter was accordingly placed before the Authority for Advance Ruling (AAR).

AAR Held

The AAR held that Section 51 of the CGST Act read with Notification No. 50/2018-Central Tax, dated 13-09-2018 empowers the Government to notify specified persons liable to deduct TDS and that the wording of the notification clearly includes authorities, boards, or bodies established by an act. It was held that a circular issued by the Department cannot override the interpretation of statutory provisions and is not binding upon quasi-judicial authorities. Accordingly, the applicant was held to be a ‘specified person’ liable to deduct TDS under Section 51 of the CGST Act. It was further clarified that the ₹2.5 lakh threshold for TDS under Section 51 of the CGST Act is determined on the value of each contract excluding GST, separate contracts with the same supplier are assessed independently, while in cases of continuous or recurrent supplies forming part of a single contract, the total contract value determines applicability of TDS.

List of Cases Referred to

• Commissioner, Customs Central Excise and Service Tax v. Shapoorji Pallonji and Company (P.) Ltd. [2023] 155 taxmann.com 303/100 GST 547/79 GSTL 145 (SC) (para 4)
• CCE v. Minwool Rock Fibre Ltd. [2012] 278 ELT 581 (SC) (para 16)
• Columbia Sportswear Company v. DIT [2012] 25 taxmann.com 470/346 ITR 161/210 Taxman 42 (SC) (para 16)
• Balmer Lawrie and Co. Ltd. v. Partha Sarathi Sen Roy [2013] 31 taxmann.com 282/119 SCL 143 (SC) (para 20)
• Indian Institute of Management, In re [2021] 129 taxmann.com 420 (AAR – TAMILNADU) (para 21).

The post IIMs Liable to Deduct GST TDS as Specified Person | AAR appeared first on Taxmann Blog.

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The Corporate Laws & Corporate Governance Committee of ICAI has issued a publication titled “Frequently Asked Questions on Section 8 Companies” to provide clarity on the legal and regulatory framework governing such entities under the Companies Act, 2013.

Section 8 companies are formed for promoting charitable or not-for-profit objectives such as commerce, art, science, education, social welfare, religion, charity, or environmental protection, and any profits earned by them must be applied solely to the promotion of these objects, without distribution of dividends to members.

The document addresses various practical questions relating to incorporation, eligibility conditions, licensing requirements, governance framework and regulatory compliances applicable to Section 8 companies. It explains the process of obtaining a licence from the Central Government, the documentation required at the time of incorporation and the conditions that must be satisfied to operate as a not-for-profit company. The publication also discusses matters relating to alteration of memorandum and articles, conversion of an existing company into a Section 8 company, and revocation of the licence in case of non-compliance.

In addition, the FAQs clarify several operational aspects such as restrictions on distribution of profits, utilisation of income, appointment of directors, maintenance of books of account and filing of statutory returns. The publication also highlights certain relaxations available to Section 8 companies under the Companies Act, 2013, recognising their not-for-profit nature and public welfare objectives.

Overall, the document serves as a practical reference for professionals, promoters and stakeholders by consolidating key regulatory provisions and addressing common queries relating to formation, governance and compliance requirements of Section 8 companies.

Click Here To Read The Full Update

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Dr Sunil Moti Lala – [2026] 184 taxmann.com 233 (Article)

1. Introduction

The International Tax Roundup for February 2026 is a comprehensive digest of critical judicial developments in the realm of international tax law. This edition covers 37 significant tax treaty decisions, providing readers with essential insights into the evolving landscape of cross-border taxation. The digest is structured to address complex legal controversies on Treaty Benefits, Permanent Establishment (PE), Business Profits, Dividends, Interest, Royalties, Fees for Technical Services (FTS), Capital Gains, and Foreign Tax Credit (FTC) mechanisms. This edition covers the judicial precedents dealing with:

(a) Treaty Benefits (2 cases) [see Para 2]

(b) Subsidiary PE and Dependent Agent PE (2 cases) [see Para 3]

(c) Business Profits, covering commission and attribution of profits (3 cases) [see Para 4]

(d) Refund of DDT in excess of the rate under DTAA (1 case) [see Para 5]

(e) Interest paid by the Indian branch and interest on refund (3 cases) [see Para 6]

(f) Royalty, covering software, database subscription, etc. (6 cases) [see Para 7]

(g) FTS, covering support charges, No FTS clause, etc. (10 cases) [see Para 8]

(h) Treaty benefits in respect of capital gains (1 case) [see Para 9]

(i) Taxability of salary earned abroad but received in India (1 case) [see Para 10]

(j) Exchange of Information under India-Hong Kong DTAA (1 case) [see Para 11]

(k) Availability of foreign tax credit due to procedural lapses (5 cases) [see Para 12]

(l) Others (2 cases) [see Para 13]

2. Treaty Benefits

2.1 Treaty Benefits – Allowed

Where assessee, a US tax resident, was denied DTAA relief solely due to delayed electronic filing of Form 10F and TRC, since neither section 90 nor Rule 21AB prescribes any time limit for filing, such procedural lapse was curable, and once filed, Form 10F would relate back to claim made in return and, thus, denial of DTAA benefit was unjustified [India – US DTAA]

DCIT (IT) v. Thogarchedu Subha Sri [2026] 183 taxmann.com 481 (Hyderabad – Trib.) [AY. 2023-24]

Assessee, a non-resident and tax resident of the USA, filed her return claiming beneficial tax rates under DTAA. However, while processing the return, CPC denied the benefit of DTAA on the grounds of non-filing of Form No. 10F, and recomputed tax under normal provisions, raising a demand. Assessee subsequently filed Form No. 10F along with TRC during rectification proceedings under section 154. Revenue contended that the due date under section 139(1) was 31-07-2023, whereas Form 10F was filed electronically only on 26-08-2024, and furnishing Form 10F was a mandatory precondition for DTAA benefits. The Tribunal held that from a combined perusal of section 90 and rule 21AB, it was evident that no time limit had been prescribed either under the Act or the rules for filing said form. Further, Form 10F did not create the right to claim the DTAA benefit; it only facilitated the verification of information. Thus, the delay in filing Form 10F was a curable procedural defect, and once the form was furnished, the same would relate back to the claim of DTAA benefit made in the return of income. [CIT (IT-4), Mumbai v. Reliance Telecom Ltd. [2021] 133 taxmann.com 41 (SC) and Principal CIT v. Wipro Ltd. [2022] 140 taxmann.com 223 (SC) distinguished]

2.2. Treaty Benefits Denied

Where the assessee, a Singapore company, was a 100 per cent subsidiary of a Hong Kong company whose ultimate parent was in China, and it had no real and continuous business activities in Singapore, exemption of capital gains on transfer of shares and CCDs of an Indian company under India-Singapore DTAA was not available, and capital gains were taxable in India. (India – Singapore DTAA)

Hareon Solar Singapore (P.) Ltd. v. Deputy CIT, IT [2026] 183 taxmann.com 125 (Delhi – Trib.) [AY. 2020-21]

Assessee, a Singapore company, subscribed to equity shares and CCDs of an Indian company in 2015 and transferred them in June 2019, claiming exemption of capital gains under section 90 read with Articles 13(4A) and 13 (5) of India–Singapore DTAA. Assessee furnished Singapore TRC and asserted satisfaction of Article 24A LOB. AO denied DTAA benefit, treating the assessee as a shell/conduit entity lacking commercial substance and taxed capital gains in India. The Tribunal noted that the assessee was a 100 per cent subsidiary of the Hong Kong company whose ultimate parent was in China; it had no employees or operational expenditure; and the bank account was operated by signatories resident in the USA and Taiwan. It concluded that since the assessee had no real and continuous business activities in Singapore and control and management were exercised outside Singapore, it was merely interposed to obtain treaty benefit and capital gains on transfer of equity shares/CCDs were taxable in India [Fullertone Financial Holdings Pte. Ltd. v. ACIT [2025] 180 taxmann.com 241 (Mumbai – Trib.) distinguished]

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Case Details: Satish Kumar Verma vs. Shri Kamta Prasad, Executive Director, U.P. State - [2026] 184 taxmann.com 79 (HC-Allahabad)

Judiciary and Counsel Details

• Rohit Ranjan Agarwal, J.
• Kalpnath Tripathi & Rajesh Shankar Srivastava for the Applicant.
• Utkarsh Birla for the Respondent.

Facts of the Case

In the instant case, the applicant filed a writ petition alleging non-compliance with the order passed by the Writ Court directing the Corporation to pay the retirement dues and salaries of its employees.

In the compliance affidavit filed by the Corporation, it was stated that the total amount payable to the applicant towards retiral dues was Rs. 15.71 lakhs. Out of this, Rs. 2.90 lakhs and Rs. 28.9 thousand were deducted under the heads ‘Protsahan Agrim’ and ‘Tyohar Agrim’. Further deductions were made towards GST and audit recovery, resulting in a total deduction of Rs. 4.55 lakhs from the retiral dues of the applicant.

It was noted that there is no provision for deducting ‘Protsahan Agrim’, ‘Tyohar Agrim’, or GST from the retirement dues of an employee of the Corporation.

High Court Held

The High Court observed that the amount received by the State Government through a soft loan for payment of retirement dues had not been properly disbursed to the employees, and that the Corporation was also not complying with the order passed by the Writ Court.

The High Court held that, as a last opportunity, one month’s time was granted to the Corporation to clear the entire retiral dues, without making any deduction from the amount payable to its employees, along with arrears of salary.

The post HC Bars Deduction of Advances and GST from Retiral Dues appeared first on Taxmann Blog.

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Case Details: ICICI Bank Ltd. vs. Punj Lloyd Ltd. - [2026] 183 taxmann.com 456 (NCLT-New Delhi)

Judiciary and Counsel Details

• Ramalingam Sudhakar, CJ. & Ravindra Chaturvedi, Technical Member
• Navin Pahwa, Sr. Adv., Aditya Vikram Singh & Ms Shreya Chandhok, Advs. for the Applicant.
• Sunil Fernandes, Sr. Adv. & Raghav Chadha, Adv. for the Respondent.

Facts of the Case

In the instant case, an application was filed by the financial creditor seeking initiation of CIRP against the corporate debtor. The application was admitted and the corporate debtor was placed under CIRP. However, the CIRP failed as the resolution plan submitted by the sole resolution applicant was not approved by the CoC.

Consequently, the members of the CoC approved a resolution for liquidation of the corporate debtor. The Liquidator conducted 14 rounds of e-auction for the sale of the corporate debtor as a going concern. The applicant company, being the successful bidder in the e-auction, sought approval of the going concern sale transaction structure for acquisition of the corporate debtor.

The applicant also sought approval of its acquisition plan along with certain reliefs and concessions.

NCLT Held

The NCLT observed that the competent authorities may consider granting such reliefs and concessions, keeping in view the objective of the Code, since the transaction involved a going concern sale. However, the amount payable by the applicant in terms of the auction to different creditors and stakeholders, and for keeping the corporate debtor as a going concern, could not be made subject to any condition, assumption, relief, concession, or qualification.

Further, the applicant would be entitled to such reliefs, concessions, or waivers as may be available or permissible under section 32A and other applicable provisions of the Code.

The NCLT held that since the applicant had purchased the corporate debtor on an “as is where is” basis, any reliefs or concessions sought in accordance with law would be examined by the concerned authorities on their own merits.

List of Cases Reviewed

• Ghanashyam Mishra & Sons (P.) Ltd. v. Edelweiss Asset Reconstruction Co. Ltd. [2021] 126 taxmann.com 132 [Para 19]
• Embassy Property Developments (P.) Ltd. v. State of Karnataka [2019] 112 taxmann.com 56/[2020] 157 SCL 445 (SC) [Para 22]; followed
• Ghanashyam Mishra & Sons (P.) Ltd. v. Edelweiss Asset Reconstruction Co. Ltd. [2021] 126 taxmann.com 132 [Para 19]
• Embassy Property Developments (P.) Ltd. v. State of Karnataka [2019] 112 taxmann.com 56/[2020] 157 SCL 445 (SC) [Para 22]; followed

List of Cases Referred to

• Ghanashyam Mishra & Sons (P.) Ltd. v. Edelweiss Asset Reconstruction Co. Ltd. [2021] 126 taxmann.com 132/227 COMP CASE 251/166 SCL 237 (SC) (para 19)
• JSW Steel Ltd. v. Pratishtha Thakur Haritwal 2025 SCC Online SC 672 (para 20)
• Vaibhav Goel v. Dy. CIT [2025] 172 taxmann.com 601/255 COMP CASE 266/188 SCL 262 (SC) (para 20)
• Shiv Shakti Inter Globe Exports (P.) Ltd. v. KTC Foods (P.) Ltd. [2022] 138 taxmann.com 511/172 SCL 249 (NCLAT- New Delhi) (para 21)
• Embassy Property Developments (P.) Ltd. v. State of Karnataka [2019] 112 taxmann.com 56/[2020] 157 SCL 445 (SC) (para 22).

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