Monthly Archives: June 2026

Consistency in Transfer Pricing methodology and prevention of double taxation on reversed provisions bind the Assessing Officer.

By | June 20, 2026
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Consistency in Transfer Pricing methodology and prevention of double taxation on reversed provisions bind the Assessing Officer. Consistency in Transfer Pricing methodology and prevention of double taxation on reversed provisions bind the Assessing Officer. Issue Whether the Transactional Net Margin Method (TNMM) at the entity level remains the most appropriate method for benchmarking international transactions… Read More »

An assessment order is legally unsustainable and deemed unreasoned if it summarily treats bank credits as unexplained under Section 68 without evaluating the explanation offered by the taxpayer.

By | June 20, 2026
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An assessment order is legally unsustainable and deemed unreasoned if it summarily treats bank credits as unexplained under Section 68 without evaluating the explanation offered by the taxpayer. Issue Whether a reassessment order passed under Section 147 read with Section 144B is legally valid if the Assessing Officer (AO) summarily treats book-entered bank credits as… Read More »

Trading results accepted without rejecting book accounts bars Section 68 additions for demonetization cash deposits.

By | June 20, 2026
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Trading results accepted without rejecting book accounts bars Section 68 additions for demonetization cash deposits. Issue Whether cash deposits made by a jeweler during the demonetization period can be treated as unexplained cash credits under Section 68 when the deposits originate from recorded sales that are fully supported by books of accounts, VAT returns, and… Read More »

Deeming fiction under Section 56(2)(x) cannot be applied retrospectively to transactions executed before its statutory effective date.

By | June 20, 2026
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Deeming fiction under Section 56(2)(x) cannot be applied retrospectively to transactions executed before its statutory effective date. Issue Whether the deeming provisions of Section 56(2)(x) can be invoked for the Assessment Year (AY) 2017-18 to tax the difference between the Stamp Duty Value (SDV) and the actual purchase consideration of a property, given that the… Read More »

Bonus shares held as long-term investments yield exempt LTCG, overriding their original stock-in-trade classification per CBDT circular.

By | June 20, 2026
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Bonus shares held as long-term investments yield exempt LTCG, overriding their original stock-in-trade classification per CBDT circular. Issue Whether the gains arising from the sale of bonus shares should be taxed as Business Income under Section 28(i) on the ground that the original underlying shares were held as stock-in-trade, or if they qualify as Long-Term… Read More »

Adjustment of gratuity against past excess trust contributions and Ind-AS book adjustments are non-disallowable tax entries.

By | June 20, 2026
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Adjustment of gratuity against past excess trust contributions and Ind-AS book adjustments are non-disallowable tax entries. Issue Whether an accounting debit for gratuity representing an adjustment against past excess contributions to an approved Gratuity Trust can be disallowed under Section 40A(7). Whether lease rentals paid without Tax Deducted at Source (TDS) can be allowed as… Read More »

Opening WDV of a block of assets cannot be disturbed to deny depreciation based on a circular.

By | June 20, 2026
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Opening WDV of a block of assets cannot be disturbed to deny depreciation based on a circular. Issue Whether the Principal Commissioner of Income Tax (PCIT) can invoke revisionary jurisdiction under Section 263 to deny depreciation on an intangible asset (NHAI concession rights) by applying CBDT Circular No. 9/2014, when the asset had already entered… Read More »

High Court will not interfere with Appellate Tribunal’s condonation of delay unless arbitrary or perverse.

By | June 20, 2026
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High Court will not interfere with Appellate Tribunal’s condonation of delay unless arbitrary or perverse. Issue Whether the High Court, exercising appellate jurisdiction, should interfere with the Appellate Tribunal’s decision to condone a 763-day delay in filing a statutory appeal by the Revenue, when the Tribunal exercised its discretion in the interest of substantial justice.… Read More »

In the absence of an FTS clause, Thai company’s technical receipts are non-taxable business profits without an Indian PE.

By | June 20, 2026
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In the absence of an FTS clause, Thai company’s technical receipts are non-taxable business profits without an Indian PE. Issue Whether, in the absence of a specific Fees for Technical Services (FTS) clause in the India-Thailand DTAA, payments received by a Thai resident company from Indian group entities for management and technical services can be… Read More »

Powering the world’s first AI arts museum

By | June 20, 2026
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Powering the world’s first AI arts museum Powering the world’s first AI arts museum   A decade-long collaboration with media artist Refik Anadol culminates in Dataland, the world’s first museum of AI arts co-founded by Refik Anadol and Efsun Erkılıç. The interactive space is powered by Google Cloud and includes a new artist residency supported… Read More »