Daily Archives: June 11, 2026

Assessing Officer Cannot Make Additions on New Issues Without Assessing the Original Grounds Used for Reopening

By | June 11, 2026
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Assessing Officer Cannot Make Additions on New Issues Without Assessing the Original Grounds Used for Reopening Issue Whether the Assessing Officer (AO) exceeds his jurisdiction by making additions under Section 68 regarding share application money received from two entities, when the sole basis and “reason to believe” recorded for reopening the assessment under Section 147… Read More »

Agricultural Land Outside Notified Municipal Limits Lacking Commercial Conversion Is Not a Capital Asset

By | June 11, 2026
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Agricultural Land Outside Notified Municipal Limits Lacking Commercial Conversion Is Not a Capital Asset Issue Whether a parcel of land sold by the assessee constitutes a “capital asset” under Section 2(14) of the Income-tax Act, thereby attracting capital gains tax, when the land is located outside notified municipal limits, is classified as agricultural in revenue… Read More »

Dismissal of SLP Confirms Revenue Cannot Raise the Issue of Netting Security Appreciation for the First Time Before High Court

By | June 11, 2026
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Dismissal of SLP Confirms Revenue Cannot Raise the Issue of Netting Security Appreciation for the First Time Before High Court Dismissal of SLP Confirms Revenue Cannot Raise the Issue of Netting Security Appreciation for the First Time Before High Court Issue Whether the Revenue is permitted to raise a new legal plea regarding the “netting… Read More »

Section 80G Approval Remanded for Fresh Examination After Tribunal Restored Assessee’s Section 12AB Charitable Registration

By | June 11, 2026
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Section 80G Approval Remanded for Fresh Examination After Tribunal Restored Assessee’s Section 12AB Charitable Registration Issue Whether a competent authority’s rejection of an application for approval under Section 80G is sustainable when the sole ground for rejection—the denial of registration under Section 12AB—has been overturned and restored in favor of the assessee by the Income… Read More »

Section 148 Reopening Notice Quashed for Assessment Year 2015-16 as Barred by Limitation Under TOLA Guidelines

By | June 11, 2026
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Section 148 Reopening Notice Quashed for Assessment Year 2015-16 as Barred by Limitation Under TOLA Guidelines Issue Whether a reassessment notice issued under Section 148 of the Income-tax Act on July 23, 2022, for Assessment Year 2015-16 is legally sustainable, given the Revenue’s binding concession recorded by the Supreme Court that such notices cannot be… Read More »

Exemption Disallowed due to Delayed Bond Investment Remanded to Verify Non-Availability of Eligible Section 54EC Bonds

By | June 11, 2026
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Exemption Disallowed due to Delayed Bond Investment Remanded to Verify Non-Availability of Eligible Section 54EC Bonds Exemption Disallowed due to Delayed Bond Investment Remanded to Verify Non-Availability of Eligible Section 54EC Bonds Issue Whether the Central Processing Centre (CPC) was justified in reducing the assessee’s claimed deduction under Section 54EC from ₹1 crore to ₹50… Read More »

Unexplained Bank Deposits Remanded for Fresh Assessment to Evaluate Profit Estimation Based on Past and Succeeding Years

By | June 11, 2026
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Unexplained Bank Deposits Remanded for Fresh Assessment to Evaluate Profit Estimation Based on Past and Succeeding Years Unexplained Bank Deposits Remanded for Fresh Assessment to Evaluate Profit Estimation Based on Past and Succeeding Years Issue Whether the Assessing Officer was justified in treating the entire cash deposit of ₹1.28 crore as unexplained money under Section… Read More »

Registration Cancellation Remanded for Re-Examination Under the Supreme Court’s Authoritative Ahmedabad Urban Development Authority Dictum

By | June 11, 2026
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Registration Cancellation Remanded for Re-Examination Under the Supreme Court’s Authoritative Ahmedabad Urban Development Authority Dictum Registration Cancellation Remanded for Re-Examination Under the Supreme Court’s Authoritative Ahmedabad Urban Development Authority Dictum Issue Whether the cancellation of a trust’s registration under Section 12AA(3) based on the amended definition of “charitable purpose” under Section 2(15) must be re-examined… Read More »

Provision for Doubtful Debts Must Be Added Back to Book Profits under Section 115JA, but Infrastructure Deduction Audit Reports Can Be Submitted at the Appellate Stage

By | June 11, 2026
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Provision for Doubtful Debts Must Be Added Back to Book Profits under Section 115JA, but Infrastructure Deduction Audit Reports Can Be Submitted at the Appellate Stage Issue Whether a provision for bad and doubtful debts must be added back to the book profits under Section 115JA of the Income-tax Act, 1961 as a provision for… Read More »

PCIT Must Apply CBDT Condonation Circular Universally to All Assessment Years to Mitigate Genuine Hardship for Form 10IC

By | June 11, 2026
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PCIT Must Apply CBDT Condonation Circular Universally to All Assessment Years to Mitigate Genuine Hardship for Form 10IC Issue Whether a Central Board of Direct Taxes (CBDT) Circular issued under Section 119(2)(b) to condone delays in filing Form 10IC to mitigate genuine hardship is applicable universally to all assessment years (including Assessment Year 2023-24), or… Read More »