Insights

Legal and tax analysis from The AS Lex

Income Tax International Tax
5 June 2026 · 8 min read

Secondment Salary Reimbursements Are Not Automatically FTS: ITAT Delhi in Honda R&D

ITAT Delhi deleted a Rs. 21.53 crore FTS addition, holding that genuine cost-to-cost salary reimbursements for seconded employees depend on real employer facts.

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Income Tax Transfer Pricing
2 June 2026 · 7 min read

Supreme Court Leaves Delhi HC's Pernod Ricard AMP Ruling Undisturbed

The Revenue's SLP failed on a 384-day delay and on merits, leaving intact key findings on AMP expenditure, Section 14A, and seized-material additions.

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Income Tax Transfer Pricing
8 March 2026 · 10 min read

Transfer Pricing Adjustment ≠ Misreporting: Madras HC Quashes Section 270A Penalty on Verizon

A landmark ruling draws a bright constitutional line — estimation-based TP adjustments cannot, in law, be equated with concealment or misrepresentation. The penalty regime has limits.

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Income Tax Transfer Pricing
5 March 2026 · 16 min read

When the Revenue Cherry-Picks: ITAT Delhi on the Limited Risk Model, Berry Ratio, and the Boundaries of the "Other Method"

A recent ITAT Delhi order doesn't just decide a case — it draws bright lines around four recurring transfer pricing and income tax controversies that affect every MNE operating in India.

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PMLA & ED
20 February 2026 · 10 min read

Ancestral or Inherited Properties Can Be Attached Under PMLA: Delhi High Court

The "it was my grandfather's house" defence is gone. A practitioner's analysis of Arun Suri v. Directorate of Enforcement and what it means for PMLA defence strategy.

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Income Tax
19 February 2026 · 12 min read

Section 148 After the 2021 Amendment: What the Supreme Court Actually Held

A practitioner's guide to the new reassessment regime — and where the battles are being fought today. Few provisions have produced as much litigation and confusion as Sections 147-151.

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Income Tax
19 February 2026 · 18 min read

The New Income Tax Bill, 2025: What Changes, What Stays, and What It Means for You

A practitioner's guide to India's biggest tax law overhaul in six decades — beyond the headlines. The Bill proposes to repeal and replace the Income Tax Act, 1961.

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Income Tax
9 March 2026 · 12 min read

ITAT Mumbai Deletes Cash Deposit Additions — Redeposits of Earlier Withdrawals Not "Unexplained"

ITAT Mumbai rules that cash redeposits from earlier bank withdrawals cannot be treated as unexplained money u/s 69A. Full analysis of Nitinkumar Kacharia v. DCIT with key takeaways.

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