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 »
Condonation Of Delay In Form 10AB And Regularisation Of Trust Registration This ruling (March 2026) provides a major procedural shield for charitable institutions struggling with the new “two-tier” registration process (Provisional to Regular). It clarifies that administrative oversights are condonable and that the Commissioner cannot reject applications on technical grounds without exercising their discretionary power.… Read More »
No Anti-Profiteering In Pure Post-GST Projects: A Legal Analysis This ruling (delivered in March 2026) clarifies the jurisdictional boundaries of Section 171 of the CGST Act. The Delhi High Court/Authority affirmed that the anti-profiteering mechanism is not a general price-control tool but a specific measure to ensure transition-period benefits reach the consumer. The Legal Issue… Read More »
The Risk Of Purchasing From Suspended Suppliers: High Court Upholds Goods Detention This ruling (delivered in early 2026) serves as a stern warning to registered traders regarding their “due diligence” obligations. The Allahabad High Court clarified that a tax invoice issued by a supplier whose registration is under suspension is legally invalid, stripping the buyer… Read More »
Deepak Agro Industries vs. State of H.P. (HP High Court): The Distinction Between “Voluntary Payment” and “Deposit Under Protest” This crucial ruling for AY 2026 (delivered on February 24, 2026) safeguards a taxpayer’s right to appeal and natural justice, specifically when the Department attempts to “force-close” proceedings by mislabeling payments. The Legal Issue Can the… Read More »
The Legal Validity Of Re-Blocking Electronic Credit Ledgers Under Rule 86A And Section 74 This ruling for AY 2025-26 (delivered in March 2026) addresses a critical tension between the “one-year cap” on blocking Input Tax Credit (ITC) and the Department’s power to protect revenue when a formal tax demand has been created. I. The Conflict:… Read More »