Daily Archives: June 23, 2026

Downward Profit Adjustments Unsustainable Without Material Proof and Financially Distressed Comparables Must Be Excluded

By | June 23, 2026
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Downward Profit Adjustments Unsustainable Without Material Proof and Financially Distressed Comparables Must Be Excluded Downward Profit Adjustments Unsustainable Without Material Proof and Financially Distressed Comparables Must Be Excluded Issue Whether a profit adjustment under Section 80-IA(10) can be sustained if the Transfer Pricing Officer (TPO) fails to provide material evidence proving a close connection, an… Read More »

Rebate Under Section 87A Cannot Be Denied on Section 112 Capital Gains for Assessment Year 2024-25

By | June 23, 2026
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Rebate Under Section 87A Cannot Be Denied on Section 112 Capital Gains for Assessment Year 2024-25 Issue Whether a resident individual opting for the new tax regime under Section 115BAC is eligible to claim a tax rebate under Section 87A against long-term capital gains taxable under Section 112, provided their total income does not exceed… Read More »

Interest Income From Mandatory Bank Deposits Is Business Income Eligible For Section 80P Deduction

By | June 23, 2026
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Interest Income From Mandatory Bank Deposits Is Business Income Eligible For Section 80P Deduction Issue Whether interest income earned by a co-operative society from statutory and compulsory deposits placed with co-operative or scheduled banks in compliance with State co-operative laws is assessable as business income eligible for deduction under Section 80P(2)(a)(i), or as income from… Read More »

Reassessment Notice Quashed as Seized Third-Party Loose Paper Failed to Establish a Live Link

By | June 23, 2026
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Reassessment Notice Quashed as Seized Third-Party Loose Paper Failed to Establish a Live Link Reassessment Notice Quashed as Seized Third-Party Loose Paper Failed to Establish a Live Link Issue Whether a reassessment notice issued under Section 148 to tax alleged “on-money” under Section 69A is valid when it is based solely on a third-party seized… Read More »

Orders Denying Capital Gains Exemption Set Aside for Failure to Consider Alternative Section 54EB Claim

By | June 23, 2026
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Orders Denying Capital Gains Exemption Set Aside for Failure to Consider Alternative Section 54EB Claim Issue Whether the tax authorities’ blanket denial of a capital gains exemption constituted a non-application of mind because they failed to consider the assessee’s alternative request to evaluate the reinvested long-term capital gains under Section 54EB after Section 54B was… Read More »