SCHEDULE I Income Tax Act 2025 [See section 9(12)] CONDITIONS FOR CERTAIN ACTIVITIES NOT TO CONSTITUTE BUSINESS CONNECTION IN INDIA 1. (1) The eligible investment fund referred to in section 9(12), means a fund established or incorporated or registered outside India, which collects funds from its members for investing it for their benefit and fulfils the following… Read More »
Penalty Quashed: AO’s Failure to Specify “Concealment” or “Inaccurate Particulars” Vitiates Penalty Proceedings. The Legal Background Section 271(1)(c) allows the AO to levy a penalty if a taxpayer has: Concealed particulars of income; OR Furnished inaccurate particulars of such income. The Procedural Error The Notice: The AO issued a notice under Section 274 (read with… Read More »
RULE 205 INCOME-TAX RULES 2026 RULE 205 INCOME-TAX RULES 2026 Furnishing of evidence of claims by employee under section 392(5)(b) for deduction of tax from income under head “Salaries”. 205. (1) The assessee shall furnish to the person responsible for making payment under section 392(1), the evidence or the particulars of the claims referred to… Read More »
A debt is not considered “taxable income” simply because it has been outstanding for a long time or is time-barred under the Limitation Act. The Dispute The Situation: The assessee had a liability of ₹2.05 crores payable to a creditor (Rockfort Gulf FZE) since FY 2011-12. The AO’s Logic: The Assessing Officer (AO) noted that… Read More »
RULE 204 INCOME-TAX RULES 2026 RULE 204 INCOME-TAX RULES 2026 Furnishing of particulars for deduction of tax at source from income under head “Salaries”. 204. (1) The assessee may furnish the following particulars in Form No. 122 to the person responsible for making the payment referred to in sub-section (1) of section 392, for the purpose… Read More »
RULE 203 INCOME-TAX RULES 2026 RULE 203 INCOME-TAX RULES 2026 Credit for tax deducted or collected at source. 203. (1) The credit for tax deducted at source or tax collected at source shall be given, on the basis of information relating to deduction or collection of tax furnished by the deductor or collector to the income-tax… Read More »
RULE 202 INCOME-TAX RULES 2026 Form and manner of filing appeal to High Court on ruling pronounced or order passed by Board for Advance Rulings under section 389(1). 202. The form and manner of filing appeal to the High Court under section 389(1) against a ruling pronounced or order passed by the Board for Advance Rulings… Read More »
High Court Quashes Reassessment: Search in 2022 Cannot Reopen AY 2012-13 as it Exceeds 10-Year Limit. The Timeline of the Case Original Assessment: For AY 2012-13, the assessment was completed in 2015, and a subsequent reassessment was completed in 2019. The Search: A search and seizure operation was conducted on the assessee (Khavda Group) on… Read More »
RULE 201 INCOME-TAX RULES 2026 Certification of copies of advance rulings pronounced by Board for Advance Rulings under section 384(8). 201. The copy of the advance ruling pronounced by the Board, to be sent to the applicant and to the Commissioner having jurisdiction over his case, shall be certified to be true copy thereof by the… Read More »
A foreign Associate Enterprise (AE) can be the “Tested Party” if it is the least complex entity in a transaction. The Tribunal upheld that the taxpayer can select its foreign AE as the tested party under the Transactional Net Margin Method (TNMM). In pharmaceutical exports, if the foreign AE performs simpler functions (like distribution) compared… Read More »