Daily Archives: June 12, 2026

Matter Remanded to Assessing Officer for De Novo Adjudication Due to Lack of Opportunity to Explain NRI Investments

By | June 12, 2026
0 Comment

Matter Remanded to Assessing Officer for De Novo Adjudication Due to Lack of Opportunity to Explain NRI Investments Matter Remanded to Assessing Officer for De Novo Adjudication Due to Lack of Opportunity to Explain NRI Investments Issue Whether an ex-parte assessment order treating time deposits, foreign currency purchases, and bank interest as unexplained investments and… Read More »

Penalty Cannot Be Sustained on Estimated Profit Additions or Unsubstantiated Loose Sheets

By | June 12, 2026
0 Comment

Penalty Cannot Be Sustained on Estimated Profit Additions or Unsubstantiated Loose Sheets Issue Whether a penalty for concealment of income under Section 271(1)(c) is legally sustainable when the underlying additions are based merely on an estimation of gross profit or on unsubstantiated loose sheets recovered during a tax proceeding. Facts The Additions: For the Assessment… Read More »

Assessment Order Under Black Money Act Quashed as TOLA Extensions Do Not Apply to Overcome Statutory Limitation

By | June 12, 2026
0 Comment

Assessment Order Under Black Money Act Quashed as TOLA Extensions Do Not Apply to Overcome Statutory Limitation Issue Whether the time-limit extensions provided under the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 (TOLA) apply to the Black Money Act, and whether an assessment order passed beyond the statutory two-year limit… Read More »

Section 153A Return Substitutes Section 139 Return, Negating Penalty Under Black Money Act for Omissions in Original Filing

By | June 12, 2026
0 Comment

Section 153A Return Substitutes Section 139 Return, Negating Penalty Under Black Money Act for Omissions in Original Filing Issue Whether a penalty under Section 43 of the Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015 can be levied for failing to report foreign assets in the original Schedule FA of… Read More »

Digital Evidence Found in Seized Mobile Phones Lacks Statutory Legs Without Strong Corroborative Material

By | June 12, 2026
0 Comment

Digital Evidence Found in Seized Mobile Phones Lacks Statutory Legs Without Strong Corroborative Material Issue Whether rough electronic notings, WhatsApp chats, unexecuted contract images, or dumb digital documents seized from a mobile phone during a search under Section 132 can form the sole basis for tax additions under Sections 68, 69, 69A, and 69C, or… Read More »

Exempt Investments Without Yield and Section 14A Disallowances Cannot Alter Book Profits or Capital Subsidies

By | June 12, 2026
0 Comment

Exempt Investments Without Yield and Section 14A Disallowances Cannot Alter Book Profits or Capital Subsidies Issue Issue 1 (Section 14A vs. Rule 8D): Whether investments that did not yield any exempt income during the year can be included in the “average value of investments” for computing disallowance under Rule 8D. Issue 2 (Section 115JB Book… Read More »

Reassessment Order Quashed as Assessing Officer Deviated from Reasons Recorded for Reopening

By | June 12, 2026
0 Comment

Reassessment Order Quashed as Assessing Officer Deviated from Reasons Recorded for Reopening Issue Whether a reassessment order under Section 147 is legally sustainable if the Assessing Officer (AO) completely deviates from the original reasons recorded for reopening the assessment and makes additions on entirely different grounds. Facts Initiation of Reassessment: For the Assessment Year (AY)… Read More »

Delay in E-Verification of Form 10B During COVID-19 to Be Condoned as Reason Was Bona Fide

By | June 12, 2026
0 Comment

Delay in E-Verification of Form 10B During COVID-19 to Be Condoned as Reason Was Bona Fide Issue Whether the delay of 113 days in the e-verification of Form No. 10B during the COVID-19 pandemic period was bona fide and deserved to be condoned under Section 119(2)(b), despite CBDT Circular No. 16/2024 restricting applications beyond three… Read More »