Monthly Archives: June 2026

Appellate authorities cannot admit additional financial evidence without recorded reasons and granting the Assessing Officer a rebuttal opportunity.

By | June 25, 2026

Appellate authorities cannot admit additional financial evidence without recorded reasons and granting the Assessing Officer a rebuttal opportunity. Issue Whether the Commissioner (Appeals) [CIT(A)] is legally justified in reducing a Section 40(a)(ia) disallowance based on new documents produced by the assessee at the appellate stage, without passing a speaking order under Rule 46A or providing… Read More »

Functionally dissimilar entities, entrepreneurs, and product developers are invalid comparables for captive IT service providers.

By | June 25, 2026

Functionally dissimilar entities, entrepreneurs, and product developers are invalid comparables for captive IT service providers. Issue Whether the Transfer Pricing Officer (TPO) was justified in including functionally dissimilar companies, full-fledged entrepreneurs, and product developers in the final list of comparables for a captive service provider, and whether the ad hoc disallowance of repair and maintenance… Read More »

Depreciation under block of assets is allowable even if manufacturing operations are discontinued during the year.

By | June 25, 2026

Depreciation under block of assets is allowable even if manufacturing operations are discontinued during the year. Issue Whether an assessee is entitled to claim depreciation on a block of assets (plant, machinery, and buildings) for an assessment year when its manufacturing operations have been discontinued, particularly when identical claims were allowed in preceding years under… Read More »

Quantified liabilities, documented payments, and reconciled books cannot be disallowed on a purely ad hoc basis.

By | June 25, 2026

Quantified liabilities, documented payments, and reconciled books cannot be disallowed on a purely ad hoc basis. Quantified liabilities, documented payments, and reconciled books cannot be disallowed on a purely ad hoc basis. Issue Whether the tax authorities can validly disallow quantified business liabilities, depreciation claims, actual statutory payments, reconciled sales turnover, and staff welfare expenses… Read More »

Application for Section 12AB registration cannot be rejected without recording a reasoned finding on specified violations.

By | June 25, 2026

Application for Section 12AB registration cannot be rejected without recording a reasoned finding on specified violations. Application for Section 12AB registration cannot be rejected without recording a reasoned finding on specified violations. Issue Whether the Commissioner (Exemptions) is justified in rejecting a trust’s application for fresh registration under section 12AB on the grounds that its… Read More »

Subsequent Section 10AA deduction disallowance via rectification order without apparent error is unsustainable.

By | June 25, 2026

Subsequent Section 10AA deduction disallowance via rectification order without apparent error is unsustainable. Subsequent Section 10AA deduction disallowance via rectification order without apparent error is unsustainable. Issue Whether the Central Processing Centre (CPC) is justified in completely disallowing an initially approved Section 10AA deduction of ₹20.29 crores through a rectification order under section 154, in… Read More »

Pending assessment proceedings must apply subsequent Section 12AA registration retrospectively, granting exemption to the assessee.

By | June 25, 2026

Pending assessment proceedings must apply subsequent Section 12AA registration retrospectively, granting exemption to the assessee. Issue Whether a charitable trust is entitled to exemptions under sections 11 and 12 for an earlier assessment year (AY 2017-18) if its Section 12AA registration was granted during the pendency of those assessment proceedings, and whether cash donations deposited… Read More »

World Surf League x Apple: How Apple Watch Changed Pro Surfing

By | June 24, 2026

World Surf League x Apple: How Apple Watch Changed Pro Surfing  World Surf League x Apple: How Apple Watch Changed Pro Surfing #AppleatPlay #Apple #Surfing See how Apple Watch handles the world’s most volatile sporting arena, helping pro surfers stay informed and in control on the Championship Tour. This is Apple at Play. Learn… Read More »

Tag Claude in, right where you already work

By | June 24, 2026

Tag Claude in, right where you already work Tag Claude in, right where you already work @Claude works right alongside your team in Slack, with the channel’s context, your org’s tools, and the persistence to see work through over days. @Claude in any thread and it picks up what the channel already knows, does the… Read More »