Daily Archives: May 22, 2026

Corporate guarantee commissions require a 50:50 interest-saving split, and Section 14A disallowances cannot increase book profits. Issue Whether the Transfer Pricing Officer (TPO) should allocate 100% of interest savings to a corporate guarantee or apply a 50:50 split between the assessee and its Associated Enterprise (AE) under the interest-saving approach. Whether an Assessing Officer (AO)… Read More »

Charitable trust’s 430-day delay in filing Form No. 10 condoned due to reasonable cause of honorary accountant’s omission. Issue Whether a 430-day delay in filing Form No. 10 for accumulation of income under Section 11(2) should be condoned under Section 119(2)(b) when the omission was caused by an honorary accountant and its rejection causes genuine… Read More »

Full sale consideration and possession transfer extinguish property rights, making capital gains taxable in AY 2018-19. Issue Whether capital gains are taxable in the assessment year when the sale consideration was paid and possession transferred, or in the subsequent year when the registered sale deed was executed. Whether the assessee is entitled to a deduction… Read More »

Cash-Based Demonetization Scheme Constitutes Benami Transaction with Legal Attachment Restricted to Extant Funds Issue Whether cash qualifies as “property” under Section 2(26) of the Prohibition of Benami Property Transactions Act (PBPT Act), 1988, making a demonetized currency deposit and subsequent bank transfer through a front entity a “benami transaction”. Whether the provisional attachment of funds… Read More »