Monthly Archives: June 2025

Rectification application for tax credits and interest calculation not decided within six months is remanded, with AO directed to complete rectification within one month. Issue: When an assessee files a rectification application under Section 154 of the Income-tax Act, 1961, providing relevant information regarding tax payments, interest calculations, and TDS credits, but the Assessing Officer… Read More »

Reopening notice beyond 3 years is invalid if the escaped income for the specific year is below Rs. 50 lakhs, even if cumulative undercharging across multiple years exceeds the threshold. Issue: Whether an Assessing Officer (AO) can issue a notice for reassessment under Section 148 of the Income-tax Act, 1961, for Assessment Year 2018-19, beyond… Read More »

Reassessment order under Section 69 quashed due to AO’s failure to dispose of assessee’s objections to reopening with a speaking order, violating natural justice. Issue: Whether a reassessment order passed by the Assessing Officer (AO) under Section 147 of the Income-tax Act, 1961, making an addition under Section 69 (unexplained investments), is valid if the… Read More »

I. PCIT cannot revise depreciation on goodwill under Section 263 if it was allowed in prior years, accepted by the Tribunal, and no factual/legal changes occurred. II. PCIT cannot revise Section 80-IA deduction under Section 263 if the AO made inquiries and accepted the claim based on furnished reconciliation, without clear findings of error or… Read More »

Denial of trust registration is remanded for fresh adjudication, as the Commissioner failed to prove non-charitable objectives or non-genuine activities, despite financial discrepancies. Issue: Whether the Commissioner (Exemptions) is justified in denying registration to a charitable trust under Section 12AB of the Income-tax Act, 1961, solely based on the financial statement not showing costs incurred… Read More »

I. Delay of 33 days in filing appeal against 12AB/80G order condoned due to assessee’s limited staff, infrequent email checks, and delayed notification by CA. II. Rejection of 12AB registration application reversed and remanded, allowing assessee to cure non-compliance (trust deed, Form 10AB, state registration, activity genuineness). I. Condonation of Delay in Filing Appeal Against… Read More »

Exemption under Section 10(23C)(iiiad) cannot be denied solely for belated return filing, especially when aggregate receipts are below the specified limit. Issue: Whether an educational institution can be denied exemption under Section 10(23C)(iiiad) of the Income-tax Act, 1961, solely on the ground that its return of income was filed belatedly under Section 148 (reassessment proceedings)… Read More »