Daily Archives: June 27, 2026

Unsecured Loan Additions Deleted upon Proving Source and Transfer Pricing Issues Remanded for Fresh Verification

By | June 27, 2026
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Unsecured Loan Additions Deleted upon Proving Source and Transfer Pricing Issues Remanded for Fresh Verification Unsecured Loan Additions Deleted upon Proving Source and Transfer Pricing Issues Remanded for Fresh Verification Issue Whether an addition under Section 68 can be sustained when the assessee provides comprehensive proof of the lender’s identity, creditworthiness, and source of funds.… Read More »

Subsequent Capital Gains Utilized for Improving an Existing Exempt Residential Property Qualify under Section 54F

By | June 27, 2026
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Subsequent Capital Gains Utilized for Improving an Existing Exempt Residential Property Qualify under Section 54F Issue Whether an assessee is entitled to claim an exemption under Section 54F of the Income-tax Act, 1961, for long-term capital gains utilized toward the further construction and structural improvement of an existing residential property, when the initial purchase of… Read More »

Mandatory Contractual Site Restoration Provisions Are Fully Deductible and Cannot Be Added Back to Book Profits

By | June 27, 2026
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Mandatory Contractual Site Restoration Provisions Are Fully Deductible and Cannot Be Added Back to Book Profits Issue Whether a provision for site restoration expenses made pursuant to a mandatory contract with the Government of India is allowable as a business deduction under Section 37(1) of the Income-tax Act, 1961. Whether such a provision constitutes an… Read More »

Contractual Site Restoration Provisions Are Fully Deductible and Reassessment Lacking Recorded Reasons Is Invalid

By | June 27, 2026
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Contractual Site Restoration Provisions Are Fully Deductible and Reassessment Lacking Recorded Reasons Is Invalid Issue Whether a provision made for site restoration expenses by a non-resident petroleum company under a Production Sharing Contract is an allowed business deduction under Section 37(1) and an ascertained liability for Section 115JA book profit computation. Whether a reassessment undertaken… Read More »

Interest Paid on Funds Borrowed for Commercial Expediency to Acquire Controlling Interest is Fully Deductible

By | June 27, 2026
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Interest Paid on Funds Borrowed for Commercial Expediency to Acquire Controlling Interest is Fully Deductible Issue Whether the interest paid on capital borrowed by an assessee to acquire shares in a company through a group concern is deductible under Section 36(1)(iii) of the Income-tax Act, 1961, when evaluated under the touchstone of commercial expediency. Facts… Read More »

Benefit of Subsequent Section 12AA Registration Applies Retrospectively to Pending Prior Year Assessments

By | June 27, 2026
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Benefit of Subsequent Section 12AA Registration Applies Retrospectively to Pending Prior Year Assessments Issue Whether the benefit of a Section 12AA registration granted in a subsequent year can be applied retrospectively to open/pending assessment proceedings for an earlier assessment year under the proviso to Section 12A(2). Whether cash donations received for religious activities and deposited… Read More »

CIT(E) Cannot Reject Section 12AB and 80G Renewals for Objects It Already Formally Approved

By | June 27, 2026
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CIT(E) Cannot Reject Section 12AB and 80G Renewals for Objects It Already Formally Approved Issue Whether the CIT(E) was justified in rejecting the renewal of registration under Section 12AB and the consequential approval under Section 80G on the procedural grounds of delayed filing after modification of objects, when the CIT(E) itself had already granted approval… Read More »

Deemed Application of Income Spent on Immovable Property Does Not Require Schedule-I Disclosure under Form I-TR7

By | June 27, 2026
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Deemed Application of Income Spent on Immovable Property Does Not Require Schedule-I Disclosure under Form I-TR7 Issue Whether the addition of approximately ₹4.00 crores was sustainable under Section 11 of the Income-tax Act, 1961, when the assessing authorities disallowed a valid utilization of “deemed application” of income from the preceding year solely due to its… Read More »

GST CASE LAWS 24.06.2026

By | June 27, 2026
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GST CASE LAWS 24.06.2-26 Relevant Act Section Case Law Title Citation Brief Summary Rajasthan GST Act, 2017 / CGST Act, 2017 Tariff Classification SGS Packaging (P.) Ltd., In re 2026 Click Here Non-biodegradable paper bags do not qualify for concessional 5% GST under Entry 319 or 322. They fall under Heading 4819 and attract 18%… Read More »

Supreme Court Allows Filing GSTAT Appeal Without Pre-Deposit Subject to Pending SLP Outcome

By | June 27, 2026
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Supreme Court Allows Filing GSTAT Appeal Without Pre-Deposit Subject to Pending SLP Outcome Supreme Court Allows Filing GSTAT Appeal Without Pre-Deposit Subject to Pending SLP Outcome Issue Whether the High Court was right to relegate the assessee to the newly operational GST Appellate Tribunal, and whether the statutory pre-deposit requirement applies to appeals arising from… Read More »