1. NOTIFICATION S.O. 3609(E) [NO. 74\/2026\/F.NO. 275\/16\/2026-IT(B)], DATED 3-
\n7-2026
\nThe CBDT vide notification dated 3 rd July, 2026, exempts TDS on aircraft and ship
\nlease payments to IFSC units.
\n2. ORDER F. NO. 225\/73\/2025-ITA-II, DATED 8-7-2026
\nThe CBDT authorised the DGIT (Systems) to upload information received under
\nAEOI to the Annual Information Statement (AIS).
\n3. NOTIFICATION S.O. 3889(E) [F. NO. 85\/2026\/F.NO.370149\/112\/2026-TPL],
\nDATED 15-7-2026
\nThe CBDT notifies \u2018384\u2019 as Cost Inflation Index for Financial Year 2026-27.
\n4. NOTIFICATION G.S.R. 656(E) [NO. 97\/2026\/F. NO. 370142\/11\/2026-TPL],
\nDATED 24-7-2026
\nThe CBDT notifies ITR-BN for block assessment under the Income-tax Act, 2025.
\n5. CBDT issues Guidance Note on Crypto-Asset Reporting Obligations under
\nIncome-tax Act, 2025
\nThe CBDT has released Guidance Note that explains the reporting obligations of
\nReporting Crypto-Asset Service Providers (RCASPs) under section 509, Rules 241
\nto 244 and Form 167. It provides practical guidance on due diligence, reporting
\nprocedures and compliance, and includes detailed FAQs aligned with the OECD's
\nCrypto-Asset Reporting Framework (CARF).<\/p>\n
Important Judicial Precedents
\nPart-A. Domestic Tax – Case Law<\/p>\n
1. SLP dismissed: sec.153C proceedings invalid absent incriminating material
\nfound during third-party search linking assessee.
\n[2026] 188 taxmann.com 640 (SC) Assistant Commissioner of Income-tax v.
\nMaulik Jayantilal Patel
\nSLP dismissed against impugned order of High Court that where no incriminating
\nmaterial relating to assessees was found during search on a third party and<\/p>\n
RNM Tax Alert \u2013 Direct Tax Part for June 2026<\/p>\n
Branch Offices: 613, Suncity Business Tower, Golf Course Road, Gurgaon- 122002
\n813 Oxford Towers, 139 Airport Road, Bangalore- 560 008<\/p>\n
Assessing Officer relied only on post-search documents and public domain data
\nwithout establishing any live nexus with assessees, invocation of section 153C and
\nissuance of notices for alleged undisclosed investment based on difference in land
\nsale consideration was unsustainable and liable to be quashed.
\n2. Multiple floors in same property under redevelopment qualify as 'one
\nresidential house' for sec. 54 exemption: ITAT
\n[2026] 188 taxmann.com 645 (Delhi – Trib.) Ranjan Sen Jain v. Income-tax
\nOfficer
\nWhere assessee, after inheriting a residential property, received basement, ground
\nand third floors as a single residential house under collaboration agreement and
\nclaimed Section 54 exemption, exemption could not be denied merely because
\nproperty comprised separate floors since what mattered was assessee acquired
\none residential unit as a whole in consequence of capital gains investment.
\n3. Unregistered sale agreement without possession transfer won't trigger
\ncapital gains taxation: ITAT
\n[2026] 187 taxmann.com 173 (Jabalpur – Trib.)\u00a0Surendra Singh v. Income-tax
\nOfficer
\nWhere assessee entered into an unregistered agreement to sell properties in 2011
\nbut retained possession until execution of registered sale deeds in assessment
\nyear 2014-15, since possession was not handed over in part performance of
\nagreement, section 2(47)(v) read with section 53A of Transfer of Property Act was
\ninapplicable and capital gains were chargeable in year of registered transfer.
\n4. Exemption u\/s 10(37) allowed on compulsory acquisition as land consistently
\nclassified agricultural: ITAT
\n[2026] 187 taxmann.com 676 (Chennai – Trib.) Sundaramahalingam
\nNarayanan v. Income-tax Officer
\nWhere assessee claimed exemption under section 10(37) on compensation
\nreceived for compulsory acquisition of land, since revenue records classified land
\nas agricultural and revenue failed to establish its conversion or use for non-
\nagricultural purposes, mere absence of agricultural income in returns could not<\/p>\n
RNM Tax Alert \u2013 Direct Tax Part for June 2026<\/p>\n
Branch Offices: 613, Suncity Business Tower, Golf Course Road, Gurgaon- 122002
\n813 Oxford Towers, 139 Airport Road, Bangalore- 560 008<\/p>\n
justify denial of exemption and thus, compensation received was entitled to
\nexemption.
\n5. Resident individual under sec. 115BAC entitled to sec. 87A rebate on STCG
\nchargeable u\/s 111A: ITAT
\n[2026] 187 taxmann.com 1011 (Mumbai – Trib.) Lisha Gajendra Marlecha v.
\nIncome-tax Department, CPC, Bengaluru
\nWhere resident individual governed by section 115BAC(1A) declared total income
\nbelow threshold prescribed under section 87A, which included short-term capital
\ngains chargeable under section 111A, rebate under section 87A could not be
\ndenied merely because part of income was chargeable under section 111A, in
\nabsence of any express statutory prohibition in sections 87A or 111A during
\nrelevant assessment year.
\n6. SLP granted: issue whether director's receipts were taxable as salary or
\nprofessional income admitted for consideration
\n[2026] 188 taxmann.com 1031 (SC) Mukesh Gupta v. Deputy Commissioner of
\nIncome-tax
\nSLP granted against order of High Court that where assessee, a director in
\ncompany, claimed receipt from company as professional\/technical service fee
\nassessable as business income but failed to produce any document evidencing
\nprofessional or technical services rendered as a financial expert, such receipt was
\nliable to be treated as salary income.
\nSLP granted against order of High Court that where assessee claimed deduction of
\ninterest on amounts borrowed and advanced to company, but failed to substantiate
\ndetails of professional or technical services to company and did not prove business
\nnexus between borrowing and advancement of funds, claim of interest expenditure
\nas business deduction and plea for commercial expediency or set-off against
\ninterest income was not allowable.<\/p>\n
Part-B. International Tax – Case Law<\/p>\n
1. AO to re-examine if automated software\/SaaS services qualified as 'technical
\nservices' under India-Ireland DTAA: ITAT<\/p>\n
RNM Tax Alert \u2013 Direct Tax Part for June 2026<\/p>\n
Branch Offices: 613, Suncity Business Tower, Golf Course Road, Gurgaon- 122002
\n813 Oxford Towers, 139 Airport Road, Bangalore- 560 008<\/p>\n
[2026] 188 taxmann.com 583 (Delhi – Trib.) SFDC Ireland ltd v. Deputy
\nCommissioner of Income-tax
\nWhere assessee, an Irish company, received revenue from Indian customers from
\nsale of software, SaaS, support and related services, and Assessing Officer sought
\nto tax receipts as FTS without examining, in light of Supreme Court's decision in
\nCIT v. Kotak Securities Ltd. [2016] 67 taxmann.com 356\/239 Taxman 139\/383 ITR
\n1 (SC), whether automated services satisfied requirements of 'technical services'
\nunder India-Ireland DTAA, matter was to be remanded for fresh adjudication.
\n2. Domestic sale prices couldn't be adopted as CUP for benchmarking export
\nsales in absence of comparable uncontrolled export transactions: ITAT
\n[2026] 187 taxmann.com 370 (Mumbai – Trib.)\u00a0Kansai Nerolac Paints Ltd. v.
\nDeputy Commissioner of Income-tax
\nWhere assessee exported water-based paints to its AE in Philippines and TPO
\nrejected TNMM and applied CUP by comparing domestic sale prices with export
\nprices without making adjustments for differences in market conditions and other
\nrelevant factors, rejection of TNMM and adoption of CUP was unjustified as
\ndomestic sales could not be adopted as CUP in absence of comparable
\nuncontrolled export transactions.
\n3. Web hosting receipts not taxable as royalty or FTS where customer had no
\nright to use or control servers: ITAT
\n[2026] 187 taxmann.com 467 (Chennai – Trib.) Deputy Commissioner of
\nIncome-tax, International Taxation v. ZOHO Corporation
\nWhere assessee, a US company, provided web hosting services through data
\ncentres located outside India and customer neither possessed nor controlled
\nservers or equipment nor acquired any right to use them, receipts from such
\nservices could not be characterised as royalty or fees for technical services under
\nsection 9(1)(vi) or article 12 of India\u2013USA DTAA; further, Explanations 4 to 6 to
\nsection 9(1)(vi) could not be imported into DTAA in absence of a corresponding
\ntreaty amendment.
\n4. No TDS required u\/s 195 as commission for procuring export orders
\nrendered outside India not taxable: ITAT
\n[2026] 188 taxmann.com 77 (Delhi – Trib.) Ajay Sharma v. Income-tax Officer<\/p>\n
RNM Tax Alert \u2013 Direct Tax Part for June 2026<\/p>\n
Branch Offices: 613, Suncity Business Tower, Golf Course Road, Gurgaon- 122002
\n813 Oxford Towers, 139 Airport Road, Bangalore- 560 008<\/p>\n
Where assessee paid commission to a Swedish intermediary for procuring export
\norders and follow-up services rendered entirely outside India, such payments
\nconstituted commission income not chargeable to tax in India, thus there was no
\nobligation to deduct tax at source under Section 195.
\n5. Corporate guarantee to AE requiring TP benchmarking is international
\ntransaction as it impacts AE's finances: ITAT
\n[2026] 187 taxmann.com 658 (Mumbai – Trib.) ACT Infraport Ltd. v. Deputy
\nCommissioner of Income-tax
\nWhere assessee, engaged in shipping and related services, furnished a corporate
\nguarantee to a bank enabling its associated enterprise to secure a term loan for
\nacquisition of a ship, such guarantee had a direct bearing on associated
\nenterprise's financial position and constituted an international transaction requiring
\ntransfer pricing benchmarking, justifying transfer pricing adjustment towards
\ncorporate guarantee commission.<\/p>\n","protected":false},"excerpt":{"rendered":"
1. NOTIFICATION S.O. 3609(E) [NO. 74\/2026\/F.NO. 275\/16\/2026-IT(B)], DATED 3- 7-2026 The CBDT vide notification dated 3 rd July, 2026, exempts TDS on aircraft and ship lease payments to IFSC units. 2. ORDER F. NO. 225\/73\/2025-ITA-II, DATED 8-7-2026 The CBDT authorised the DGIT (Systems) to upload information received under AEOI to the Annual Information Statement (AIS). 3. NOTIFICATION S.O. 3889(E) [F.<\/p>\n","protected":false},"author":2,"featured_media":0,"comment_status":"open","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"footnotes":"","_links_to":"","_links_to_target":""},"categories":[16],"tags":[],"class_list":["post-3154","post","type-post","status-publish","format-standard","hentry","category-direct-tax"],"yoast_head":"\n