Daily Archives: September 18, 2025

CBDT has notified the “Tamil Nadu Electricity Regulatory Commission” under section 10(46) MINISTRY OF FINANCE (Department of Revenue) (CENTRAL BOARD OF DIRECT TAXES) NOTIFICATION NewDelhi,   the 15th September,2025 S.O. 4167(E).—In exercise of the powers conferred by sub-clause (b) of clause (46A) of section 10 of the Income-tax Act, 1961 (43 of 1961), (hereinafter referred… Read More »

I. On Management Fees and the ‘Make Available’ Clause Management Fee Isn’t Taxable as FTS Because Support Services Don’t ‘Make Available’ Technical Know-How Under the India-Singapore DTAA. Issue Can management fees for support and advisory services be taxed as Fees for Technical Services (FTS) under Article 12 of the India-Singapore tax treaty if the services… Read More »

I. On Reassessment Notice Lacking a DIN Reassessment Invalidated as Initiating Notice Lacked a Mandatory Document Identification Number (DIN). Issue Is a reassessment notice under section 148 of the Income-tax Act, 1961, legally valid if it’s issued without a Document Identification Number (DIN), and can this fundamental defect be fixed later? Facts For the Assessment… Read More »

Reassessment Quashed as Notice for AY 2013-14 Was Issued Beyond the Time Limit Calculated per the Rajeev Bansal Ruling. Issue Whether a reassessment notice issued under the new regime on July 25, 2022, for the Assessment Year 2013-14, was barred by limitation, thereby rendering the subsequent assessment order invalid. Facts The assessee, an Association of… Read More »

Delay in Filing Form 10-IC Condoned as Bona Fide Intent Was Evident from Simultaneous Filing with Return. Issue Whether a minor delay in filing Form 10-IC to opt for the concessional tax regime under section 115BAA of the Income-tax Act, 1961, should be condoned, especially when the assessee’s intent was clear and the delay was… Read More »

  I. On Reassessment Notice Lacking a DIN Reassessment Order Quashed as the Initiating Notice Under Section 148 Lacked a Mandatory DIN. Issue Is a reassessment notice issued under section 148 of the Income-tax Act, 1961, legally valid if it does not contain a Document Identification Number (DIN), and can a subsequent assessment order based… Read More »

Reassessment Notice Upheld as AO’s Belief of Bogus Purchases was Based on Tangible Information. Issue Whether the initiation of reassessment proceedings under section 148A of the Income-tax Act, 1961, was legally valid, based on the Assessing Officer’s (AO) prima facie belief that the assessee had engaged in bogus purchase transactions, leading to an escapement of… Read More »

On Admission of Additional Evidence (Section 68) Additional Evidence Admitted with Costs in the Interest of Substantial Justice, Despite Assessee’s Casual Approach. Issue Whether additional evidence, having a material bearing on the issue of unsecured loans, should be admitted at the Appellate Tribunal stage under Rule 29, even when the assessee’s failure to produce it… Read More »

An Ex-parte Penalty Order Passed Without a Proper Hearing Violates Natural Justice and Must Be Quashed. Issue Whether a penalty order passed ex-parte under section 271D of the Income-tax Act, 1961, is valid if the assessee was not granted an opportunity of being heard, thereby violating the principles of natural justice. Facts The assessee was… Read More »