Daily Archives: April 22, 2026

Form 57 Income Tax Rules 2026 pdf download and Key points

By | April 22, 2026

Form 57 Income Tax Rules 2026 pdf download and Key points Form 57 Income Tax Rules 2026 pdf download and Key points FORM NO. 57 [See rule 123(4)] Intimation by a designated constituent entity, resident in India, of an international group, for the purposes of section 171(4) Under the Income-tax Rules, 2026, Form No. 57… Read More »

Form 56 Income Tax Rules 2026 pdf download and Key points

By | April 22, 2026

Form 56 Income Tax Rules 2026 pdf download and Key points Form 56 Income Tax Rules 2026 pdf download and Key points FORM NO. 56 [See rule 123] MASTER FILE Information and document to be furnished by the person who is a constituent entity under section 171(4) Under the Income-tax Rules, 2026, Form No. 56… Read More »

Important Income Tax Case Laws 21.04.2026

By | April 22, 2026

Important Income Tax Case Laws 21.04.2026 Section Case Law Title Key Ruling Summary Citation Sec 11 & 12 Prof. J.P. Trivedi Memorial Trust Procedural Lapses: Exemption cannot be denied for delayed electronic filing of Form 10/10B or failing to specify accumulation purposes, as these are not “fatal” errors. Click Here Sec 92C Xchanging Solutions Ltd.… Read More »

Form 55 Income Tax Rules 2026 pdf download and Key points

By | April 22, 2026

Form 55 Income Tax Rules 2026 pdf download and Key points Form 55 Income Tax Rules 2026 pdf download and Key points FORM NO. 55 [See rule 121] Form of application for an assessee, resident in India, seeking to invoke mutual agreement procedure provided for in agreements with other countries or specified territories Under the… Read More »

Search on others cannot extend third-party reassessment limits without specific seized material pertaining to them.

By | April 22, 2026

Search on others cannot extend third-party reassessment limits without specific seized material pertaining to them. The Dispute: Section 148 vs. Section 153C The Conflict: The Revenue searched the “SMC Group” and suspected the assessee of taking a loan from a shell entity. They issued a reassessment notice on 30-08-2024 for AY 2016-17, trying to use… Read More »

Assessment orders passed in the name of a company that has ceased to exist due to amalgamation are void ab initio.

By | April 22, 2026

Assessment orders passed in the name of a company that has ceased to exist due to amalgamation are void ab initio. The Dispute The Amalgamation: Two companies, RPPL and RPEL, merged into the assessee-company (RIL). The Revenue’s Action: Despite being explicitly informed of the merger and acknowledging it (evidenced by earlier refund adjustments in RIL’s… Read More »

Failure by DRP to follow Tribunal remand directions results in automatic exclusion of disputed comparables.

By | April 22, 2026

Failure by DRP to follow Tribunal remand directions results in automatic exclusion of disputed comparables. The Dispute For AY 2011-12, five comparable companies selected by the Transfer Pricing Officer (TPO) were challenged by the assessee. The Tribunal had previously sent these back to the DRP for a fresh look. However, the DRP failed to pass… Read More »

Delayed Form 10 filing is a procedural lapse that cannot deny substantive tax exemption.

By | April 22, 2026

Delayed Form 10 filing is a procedural lapse that cannot deny substantive tax exemption. The Dispute: Technical Non-Compliance vs. Charitable Intent The Conflict: The assessee-trust followed the 85% application rule but chose to accumulate the remaining income under Section 11(2). The Assessing Officer (AO) disallowed this because: Form 10 (Notice of accumulation) was filed after… Read More »

Reassessment cannot be based on “assumptions” or broad survey findings from other years without specific material for the relevant year.

By | April 22, 2026

Reassessment cannot be based on “assumptions” or broad survey findings from other years without specific material for the relevant year. The Context The case involved the GE Group in India. The Revenue attempted to reopen assessments for AY 2013-14 and 2014-15 using two different procedural regimes (the pre-2021 regime and the newer Section 148A regime).… Read More »

Form 54 Income Tax Rules 2026 pdf download and Key points

By | April 22, 2026

Form 54 Income Tax Rules 2026 pdf download and Key points Form 54 Income Tax Rules 2026 pdf download and Key points FORM NO. 54 [See rule 119] Application for Renewal of an Advance Pricing Agreement (APA) Under the Income-tax Rules, 2026, Form No. 54 is a newly introduced form that acts as the Application… Read More »