Daily Archives: February 26, 2026

Failure to Record Satisfaction and Violation of Section 269SS Precludes the Levy of Section 271D Penalties Issue Whether a penalty under Section 271D can be legally sustained when the Assessing Officer (AO) fails to record a specific finding of a Section 269SS violation or express “satisfaction” regarding penal consequences during the assessment proceedings. Facts The… Read More »

New Office Premises Purchased via Registered Agreements are ‘Acquired’ and Includible in the Block of Assets Regardless of Possession or Use Issue Whether newly purchased commercial office premises, acquired via registered agreements within the financial year, can be included in the “block of assets” under Section 50 to offset capital gains, even if the assessee… Read More »

Artificial Creation of Goodwill via Intragroup Merger Is a Colourable Device Ineligible for Depreciation and Buy-back Tax Benefits Issue I: Depreciation on Goodwill Whether depreciation under Section 32 is allowable on “Goodwill” created during the merger of two subsidiaries of the same holding company, where no actual business was added and the transaction involved no… Read More »

The Revenue Cannot Demand Tax Directly from an Employee if the Employer Deducted TDS but Failed to Deposit It Issue Whether the Income Tax Department can raise a tax demand against an individual employee under Section 143(1) when their employer has deducted Tax Deducted at Source (TDS) from their salary but failed to remit that… Read More »