Daily Archives: October 14, 2025

The increased 10% safe harbour limit for the difference between the stamp duty value and the actual consideration of a property is curative and applies retrospectively. Issue Is the amendment to Section 56(2)(x) of the Income-tax Act, 1961, which increased the permissible tolerance limit between the stamp duty value and the sale consideration from 5%… Read More »

An appellate authority cannot direct an Assessing Officer to reopen an assessment for a past year if, on the date the direction is given, that past year was already barred by the normal statute of limitations for reopening. Issue Does the power of an Assessing Officer to reopen an assessment for any past year, based… Read More »

An unrealized gain from the year-end valuation of open share trading positions is not taxable income. Issue Can a notional, unrealized gain, which arises from the mark-to-market (MTM) valuation of unsold or unsettled share trading positions at the end of the financial year, be treated as the taxable income of the assessee for that year?… Read More »

A TP adjustment is invalid if the TPO fails to find defects in the assessee’s study. Issue Can a Transfer Pricing Officer (TPO) make an adjustment by comparing the margins of a company’s tax-holiday units with its non-tax holiday units, if the TPO has not first identified and recorded specific defects in the taxpayer’s own… Read More »

A non-speculative business loss can be set off against capital gains income. Issue Can a business loss, specifically a non-speculative loss arising from trading in futures and options (F&O), be legally set off against income earned under the head “Capital Gains” under the provisions of the Income-tax Act, 1961? Facts For the Assessment Year 2009-10,… Read More »

A deduction was allowed based on the rule of consistency. Issue Can an Assessing Officer (AO) deny a tax deduction on a recurring issue that has already been settled in the taxpayer’s favour by the Income Tax Appellate Tribunal (ITAT) in a prior year, solely on the grounds that the revenue department has filed an… Read More »

A revised return opting for the 115BAA regime is valid. Issue Can a company switch to the concessional tax regime under Section 115BAA of the Income-tax Act, 1961, by filing a revised return, and can it set off its normal brought-forward business and capital losses against the income computed under this new regime? Facts An… Read More »

ITR REFUND Processing रुकी हुई ITR हुई प्रोसेस ! INCOME TAX LATEST UPDATE