Daily Archives: March 17, 2026

Remand For Trust Exemption and Quashing Of Penalty On Cash Sale Consideration This ruling (delivered in March 2026) provides two major victories for taxpayers: it reaffirms that charitable income must be computed on commercial principles even if exemptions are denied, and it strictly limits the scope of penalty for cash transactions involving immovable property. I.… Read More »

Judicial Relief For Cooperatives: Waiver Of Section 234B Interest Due To Legal Ambiguity And High Court Precedents This ruling for AY 1998-99 offers vital protection for taxpayers—particularly Public Sector Undertakings (PSUs) and Cooperative Societies—who default on advance tax due to conflicting judicial interpretations. The Legal Issue Can interest under Section 234B be waived if a… Read More »

Bogus Sales Verification and Limitation Periods for Reassessment: A Legal Analysis This ruling addresses two critical aspects of tax litigation: the evidentiary requirements for proving the genuineness of business sales and the strict application of time limits for reopening old assessments following recent Supreme Court precedents. I. Bogus Sales and the “Source vs. Turnover” Conflict… Read More »

Transfer Pricing Consistency and the Admissibility of Fresh Claims During Assessment This ruling for AY 2018-19 (delivered in March 2026) reinforces two critical taxpayer rights: the priority of the Internal CUP method in Transfer Pricing and the duty of the Assessing Officer (AO) to entertain legitimate business deductions even if they were missed in the… Read More »

Consistency In Judicial Precedents And The Limits Of Revisionary Power This ruling (delivered in February 2026) reinforces the principle that once an issue has been factually and legally settled by a Tribunal, the Department cannot ignore that history to reopen the case under Section 263. The Legal Issue Scope of Revision (Section 263): Can a… Read More »

Expanding Exemption Limits: Multiple Properties And Filing Deadlines Under Section 54 This ruling for AY 2012-13 provides critical relief for taxpayers regarding the flexibility of Section 54. It addresses two major points of contention: whether “a residential house” means exactly one house, and whether the Capital Gains Account Scheme (CGAS) is an absolute barrier to… Read More »

The Legal Protection Of Disclosed Bank Withdrawals And Rejection Of Ad Hoc Tax Disallowances This ruling for AY 2014-15 to 2016-17 provides a significant defense for businesses that operate with high cash volumes. It clarifies that once the “source” of money is identified, the tax department cannot penalize a taxpayer simply because it “doubts” how… Read More »

Delayed Filing Of Form 10B: Condoning Procedural Lapses For Substantive Justice This ruling for AY 2023-24 provides vital relief for charitable trusts that struggled with the transition to the “New” Audit Report format. It establishes that technical hurdles and late software releases by the Department constitute a “reasonable cause” for delay. The Legal Issue Can… Read More »