The Revenue cannot make a “protective addition” permanent without first determining the actual owner of the income. The Dispute The assessee sold a property registered in his wife’s name, offered the capital gains in his own return, and claimed the Section 54F exemption (reinvestment in a residential house). The AO’s Error: The Assessing Officer made… Read More »
TP Interest on Receivables Benchmarked at LIBOR+200bps; WCA Mandatory Under TNMM. I. Transfer Pricing: Comparability & Adjustments 1. Functional Differences (Business Support Services) The Verdict: A company that sells packaged software/technology solutions is not a valid comparable for an assessee providing routine Business Support Services (BSS). Logic: Products/Software have different risk profiles and profit drivers… Read More »
Deductor and deductee meaning for TDS in India Deductor and deductee meaning for TDS in India In the context of Tax Deducted at Source (TDS), the transaction is split between two parties: 1. The Deductor (The Payer) The Deductor is the person or entity making a payment (like an employer paying salary or a company… Read More »
Tax Identification Number (TIN) of a remittee ! Explained Income Tax Act 2025 Tax Identification Number (TIN) of a remittee ! Explained Income Tax Act 2025 The Tax Identification Number (TIN) of a remittee (the person or entity receiving a payment, typically a non-resident) refers to the specific tax registration number allotted to them by… Read More »
Farming for the future on Where the Internet Lives Farming for the future on Where the Internet Lives This is the story of Alphabet’s moonshot, Heritable Agriculture. At Heritable’s lab in the Bay Area, CEO Brad Zamft and his team are developing a platform that can predict which genetic combinations will thrive in specific climates… Read More »
Tax Residency Certificate in Income Tax Act 2025 of India Explained with example Tax Residency Certificate in Income Tax Act 2025 of India Explained with example What is Tax Residency Certificate Under the Income-tax Act, 2025, a Tax Residency Certificate (statutorily referred to as a “certificate of his being a resident”) is a mandatory document for… Read More »
Important GST Case Laws 16.04.2026 Relevant Act Section / Rule Case Law Title Citation Brief Summary CGST Act, 2017 Sec 9 Ezhumalaiyan Construction v. State Tax Officer Click Here Increased GST rate (18%) applies to all supplies made after 18.07.2022, regardless of prior lower-rate contracts; differential tax demand is valid. CGST Act, 2017 Sec 15… Read More »
Appeals Filed in Wrong Jurisdiction Due to Dept. Confusion Must Be Transferred, Not Rejected. The Dispute: The “Common Order” Jurisdictional Trap The Conflict: An insurance company received a single Common Order-in-Original from an Additional Commissioner. This order covered the insurer’s tax liabilities for multiple offices across India. The Petitioner’s Action: For the portion of the… Read More »
GST Credit Blocks Automatically Expire After One Year; Continued Restriction is Illegal Under Rule 86A. The Dispute: Statutory Sunset vs. Administrative Inertia The Conflict: The petitioner’s Electronic Credit Ledger (ECL) was blocked by the department on November 21, 2024. The Petitioner’s Stance: By the time the petition was filed in early 2026, the block had… Read More »
Ignoring a Fresh Hearing Request After Additional Submissions Violates Section 75(4) and Natural Justice. The Dispute: The “Mid-Adjudication” Silence The Conflict: The petitioner followed the standard adjudication process, appearing for a personal hearing on July 11, 2025. However, the situation evolved: The New Evidence: On August 14, 2025, the petitioner filed an additional reply raising… Read More »