Daily Archives: April 25, 2026

Karnataka HC: No GST on Pigmy Agent Commissions as They are Bank Employees, Not Contractors.

By | April 25, 2026

Karnataka HC: No GST on Pigmy Agent Commissions as They are Bank Employees, Not Contractors. The Dispute: Business Facilitator vs. Bank Employee The Conflict: The Revenue conducted an inspection of the Rural Bank and issued Form GST DRC-01A, proposing to levy GST under the Reverse Charge Mechanism (RCM) on commissions paid to “Pigmy Agents” (doorstep… Read More »

Category: GST

AAR Ruling: RWA Corpus Funds Are Taxable at the Time of Receipt Without the ₹7,500 Exemption.

By | April 25, 2026

AAR Ruling: RWA Corpus Funds Are Taxable at the Time of Receipt Without the ₹7,500 Exemption. 1. The Nature of Supply: Corpus Fund is “Supply” The Dispute: The RWA argued that the Corpus Fund is a capital contribution from members for future contingencies (like painting or lift replacement) and should not be treated as a… Read More »

Category: GST

Important Income Tax Case Laws 25.04.2026

By | April 25, 2026

Important Income Tax Case Laws 25.04.2026 Relevant Act Section / Authority Case Law Title Citation Brief Summary Income-tax Act, 1961 Sec 2(24) / 115JB Graphite India Ltd. v. CIT Click Here Capital Subsidy: Sales tax remission linked to fixed capital investment is a capital receipt; not taxable and excluded from MAT (Sec 115JB). Income-tax Act,… Read More »

Pre-2002 Self-Generated Trademark Transfers are Tax-Free as Cost of Acquisition is Unascertainable.

By | April 25, 2026

Pre-2002 Self-Generated Trademark Transfers are Tax-Free as Cost of Acquisition is Unascertainable. I. The Sarabhai Zydus Case: Transfer of Trademarks The Dispute: The assessee transferred 22 veterinary brand names to a joint venture for ₹29.10 crores. The Revenue tried to tax this under three different heads: Capital Gains (with Nil cost), Business Income (Section 28(iv)),… Read More »

TDS Credit Denied to Agents if Underlying Income Belongs to the Principal/Farmer.

By | April 25, 2026

TDS Credit Denied to Agents if Underlying Income Belongs to the Principal/Farmer. The Dispute: The Agent, The Farmer, and the Missing Income The Scenario: The assessee is a commission agent at an APMC (Agricultural Produce Market Committee). He facilitates auctions where traders buy produce from farmers. The Transaction: Traders purchased agricultural produce. Under Section 194Q,… Read More »

Search Additions Based on Estimated Yield Comparisons Without Incriminating Material Are Legally Invalid.

By | April 25, 2026

Search Additions Based on Estimated Yield Comparisons Without Incriminating Material Are Legally Invalid. The Dispute: Expected Yield vs. Actual Yield The Scenario: The assessee, a steel re-rolling company, declared a production yield of 82.42%. However, the AO noted that during a previous search-period assessment (covering 2006-07 to 2012-13), the estimated yield was 89%. The AO’s… Read More »

SC Reaffirms: Reassessments for AY 2016-17 and Earlier Are Barred if Already Time-Expired Under Old Law.

By | April 25, 2026

SC Reaffirms: Reassessments for AY 2016-17 and Earlier Are Barred if Already Time-Expired Under Old Law. The Dispute: The SMC Group Search & The 2024 Notice The Conflict: The Revenue conducted a search on the SMC Group and suspected that the assessee had taken an “accommodation entry” (loan) from one of the group’s shell entities.… Read More »

Late Filing of Form 10DA is a Procedural Lapse; Deduction Under Section 80JJAA Cannot Be Denied if Filed Before Assessment.

By | April 25, 2026

Late Filing of Form 10DA is a Procedural Lapse; Deduction Under Section 80JJAA Cannot Be Denied if Filed Before Assessment. The Dispute: Substance vs. Procedure The Conflict: The assessee claimed a deduction for hiring new employees. However, the Assessing Officer (AO) disallowed the entire claim because the required audit report (Form 10DA) was filed after… Read More »

Scholarships for Foreign Studies Paid in India Are Domestic Application; Registration Cannot Be Denied.

By | April 25, 2026

Scholarships for Foreign Studies Paid in India Are Domestic Application; Registration Cannot Be Denied. The Dispute: Indian Students, Foreign Degrees, and Section 11(1)(c) The Conflict: The assessee-trust applied for registration under Section 12AB. During the enquiry, the CIT(Exemption) found that the trust had granted scholarships to Indian students to study abroad. The Revenue’s Objection: The… Read More »