Daily Archives: June 18, 2026

Consistency in Transfer Pricing Methods and Business Deductions Upheld, While Additional Depreciation Requires Integral New Capital Acquisition

By | June 18, 2026
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Consistency in Transfer Pricing Methods and Business Deductions Upheld, While Additional Depreciation Requires Integral New Capital Acquisition Issue Whether the Internal Transactional Net Margin Method (TNMM) can be replaced by the Comparable Uncontrolled Price (CUP) method if the Tribunal and High Court have consistently accepted TNMM for identical transactions in previous years. Whether Transfer Pricing… Read More »

CIT(A) Cannot Change Addition Sections Without Specific Notice, and Unreasonable Ad Hoc Disallowances Must Be Reduced

By | June 18, 2026
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CIT(A) Cannot Change Addition Sections Without Specific Notice, and Unreasonable Ad Hoc Disallowances Must Be Reduced Issue Whether the Commissioner of Income-tax (Appeals) [CIT(A)] can change the legal section of a tax addition (from Section 69C to Section 68) without issuing a specific show-cause notice to the assessee. Whether an ad hoc disallowance of 20%… Read More »

Deductions Under Section 80HHC Are Not Reduced by Section 80IA, and Capital-Linked Sales-Tax Remissions Are Capital Receipts

By | June 18, 2026
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Deductions Under Section 80HHC Are Not Reduced by Section 80IA, and Capital-Linked Sales-Tax Remissions Are Capital Receipts Issue Whether business profits must be reduced by deductions allowed under Section 80IA while computing the deduction under Section 80HHC of the Income-tax Act, 1961. Whether a sales-tax remission granted under the West Bengal Incentive Scheme, 1993—explicitly linked… Read More »

Deductions Under Section 80HHC Are Not Reduced by Section 80IA, and Capital-Linked Sales-Tax Remissions Are Capital Receipts

By | June 18, 2026
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Deductions Under Section 80HHC Are Not Reduced by Section 80IA, and Capital-Linked Sales-Tax Remissions Are Capital Receipts Deductions Under Section 80HHC Are Not Reduced by Section 80IA, and Capital-Linked Sales-Tax Remissions Are Capital Receipts Issue Whether business profits must be reduced by deductions allowed under Section 80IA while computing the deduction under Section 80HHC of… Read More »