Daily Archives: June 6, 2026

Department Cannot Adjust Existing Refunds Against a Disputed Demand While a Stay Application and Appeal Remain Pending Issue Whether the Income Tax Department is legally permitted under Section 245 to adjust a tax refund due to an assessee for one year (AY 2021-22) against a disputed outstanding tax demand of a subsequent year (AY 2023-24),… Read More »

High Net Profit Estimation Reduced to 4% for Wholesale Trade, and Penalties Cancelled Due to Genuine Digital Hardships and Assessing Officer’s Waiver Issue Issue I (Business Income Estimation): Whether a 5% estimated net profit rate on an un-audited turnover is excessive for a wholesale medicine business, considering past and succeeding year margins, and whether it… Read More »

Professional’s Death Forms Valid Condonation Ground, and Section 151 Approval Flaw Striking at Root of Matter Cannot Be Blocked by Limitation Professional’s Death Forms Valid Condonation Ground, and Section 151 Approval Flaw Striking at Root of Matter Cannot Be Blocked by Limitation Issue Primary Issue (Condonation of Delay): Whether the death of an assessee’s authorized… Read More »

AO Directed to Treat Section 148 Return as Filed Under Section 139 to Grant Full Refund of Excess Prepaid Taxes Issue Whether an Assessing Officer (AO) can restrict the benefit of prepaid taxes (TDS and Advance Tax) solely to the extent of the outstanding tax demand, and deny the refund of the balance amount, on… Read More »

Denial of TDS Credit Is Unjustified Once Corresponding Receipts Form 26AS Are Fully Taxed in Reassessment Proceedings Issue Whether an assessee can be denied credit for Tax Deducted at Source (TDS) on technical grounds when the corresponding income/receipts reflected in Form 26AS have been explicitly brought to tax by the Assessing Officer in reassessment proceedings… Read More »

No Disallowance of Interest Under Rule 8D(2)(ii) If Assessee Possesses Sufficient Own Funds To Cover Exempt Income Investments Issue Whether any disallowance of interest expenses can be made under Section 14A of the Income-tax Act, 1961, read with Rule 8D(2)(ii) of the Income-tax Rules, 1962, when the assessee possesses sufficient interest-free own funds (share capital… Read More »

Late PF/ESI Deposit During COVID-19 Involves Debatable Legal Interpretation Beyond Section 143(1) Adjustment Powers Issue Whether the Central Processing Centre (CPC) was justified in making a prima facie adjustment under Section 143(1), and subsequently rejecting a Section 154 rectification application, to disallow employees’ PF and ESI contributions deposited after the due date under respective labor… Read More »