Daily Archives: January 1, 2026

Section 263 Revision Invalid When Issue (Bogus Purchases) is Already Subject Matter of Appeal Before Commissioner (Appeals) ISSUE Whether the Principal Commissioner of Income Tax (PCIT) can validly initiate revision proceedings under Section 263 on a specific issue (bogus purchases/sales) when the same issue is already under challenge in an appeal filed by the assessee… Read More »

Condonation of Delay in Filing Form 10B/10 Allowed Beyond 3 Years Limit Due to COVID-19 and Pending Appeal Proceedings ISSUE Whether the Commissioner (Exemptions) was justified in rejecting the application for condonation of delay in filing Form 10B (Audit Report) and Form 10 (Accumulation of Income) solely on the ground that it was filed beyond… Read More »

Monetary Reimbursement of Realized Forex Loss by AE Not Taxable as Perquisite under Section 28(iv) ISSUE Whether a cash reimbursement received by the assessee from its Associated Enterprise (AE) to compensate for a realized foreign exchange loss on capital repayment is chargeable to tax as a “benefit or perquisite” under Section 28(iv), especially when the… Read More »

Monetary Reimbursement of Realized Forex Loss by AE Not Taxable as Perquisite under Section 28(iv) ISSUE Whether a cash reimbursement received by the assessee from its Associated Enterprise (AE) to compensate for a realized foreign exchange loss on capital repayment is chargeable to tax as a “benefit or perquisite” under Section 28(iv), especially when the… Read More »