Monthly Archives: June 2026

On-Ground Sales and Marketing Support Rendered to Foreign Clients Qualifies as Taxable Intermediary Services in India

By | June 15, 2026
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On-Ground Sales and Marketing Support Rendered to Foreign Clients Qualifies as Taxable Intermediary Services in India Issue Whether sales, marketing consulting, and HR advisory services provided on-ground in India by a domestic supplier to a Malaysian client for its Indian engagement constitute “intermediary services” under Section 2(13) of the IGST Act, 2017, thereby shifting the… Read More »

INCOME TAX CASE LAW 15.06.2026

By | June 15, 2026
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INCOME TAX CASE LAW 15.06.2026 INCOME TAX CASE LAW 15.06.2026 Relevant Act Section Case Law Title Citation Brief Summary Income-tax Act, 1961 Section 10(23FBA) Deputy Commissioner of Income-tax v. Sundaram Alternative Opp Series High Yield Secured Debt fund Click Here Processing fees on NCD investments are intrinsically linked to investment risks and overall yield. They… Read More »

An Intimation Under Section 143(1) Does Not Merge Into a Section 143(3) Scrutiny Order, and Adjustments Must Be Appealed Separately

By | June 15, 2026
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An Intimation Under Section 143(1) Does Not Merge Into a Section 143(3) Scrutiny Order, and Adjustments Must Be Appealed Separately Issue Whether adjustments made in an intimation under Section 143(1) merge into a subsequent scrutiny assessment order passed under Section 143(3) (which merely adopted the 143(1) figures without independent modifications), thereby allowing the assessee to… Read More »

Reassessment Notices Issued Beyond the Recomputed Supreme Court Timeline and TOLA Extensions Are Time-Barred and Invalid

By | June 15, 2026
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Reassessment Notices Issued Beyond the Recomputed Supreme Court Timeline and TOLA Extensions Are Time-Barred and Invalid Issue Whether the reassessment order passed under Section 148A(d) and the subsequent notice issued under Section 148 on July 29, 2022, for Assessment Year 2014-15, are legally sustainable or invalid as being barred by the law of limitation. Facts… Read More »

Mandatory CSR Expenditures to Registered Trusts Qualify for Section 80G Deductions and Working Capital Adjustments Preclude Separate Interest Imputation on Delayed Receivables

By | June 15, 2026
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Mandatory CSR Expenditures to Registered Trusts Qualify for Section 80G Deductions and Working Capital Adjustments Preclude Separate Interest Imputation on Delayed Receivables Issue Whether an assessee can claim a tax deduction under Section 80G for corporate donations made to a registered, approved trust, even if that expenditure forms part of its mandatory Corporate Social Responsibility… Read More »

Forex Fluctions on Export Proceeds are Operating in Nature and CSR Donations Qualify for Section 80G Deductions

By | June 15, 2026
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Forex Fluctions on Export Proceeds are Operating in Nature and CSR Donations Qualify for Section 80G Deductions Issue Whether foreign exchange gains/losses arising from the realization of normal export proceeds from Associated Enterprises (AEs) should be treated as operating in nature when computing the Profit Level Indicator (PLI) under the Transactional Net Margin Method (TNMM).… Read More »

Tax Authorities Cannot Arbitrarily Reverse Multi-Year Deductions or Disallow Reimbursed Employee ESOP Costs, But Share Issue Expenses Remain Capital in Nature

By | June 15, 2026
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Tax Authorities Cannot Arbitrarily Reverse Multi-Year Deductions or Disallow Reimbursed Employee ESOP Costs, But Share Issue Expenses Remain Capital in Nature Issue Whether the Assessing Officer is justified in disallowing a multi-year amortization deduction under Section 35D in its final (5th) year when the same deduction was accepted and allowed without disturbance by the Revenue… Read More »

Serving Notice Solely Through the ITBA Portal is Invalid and Cannot Justify Denying Trust Registration or Approvals

By | June 15, 2026
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Serving Notice Solely Through the ITBA Portal is Invalid and Cannot Justify Denying Trust Registration or Approvals Issue Whether serving statutory notices exclusively through the Income Tax Business Application (ITBA) portal constitutes a valid method of service under Section 282(1) read with Rule 127(1), and whether an application for fresh registration under Section 12AB can… Read More »

AIF Investment and Processing Fees Income Cannot Be Arbitrarily Reclassified as Taxable Business Income

By | June 15, 2026
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AIF Investment and Processing Fees Income Cannot Be Arbitrarily Reclassified as Taxable Business Income Issue Whether the Assessing Officer was justified in re-characterizing the interest income, short-term capital gains, and processing fees of a SEBI-registered Category II Alternative Investment Fund (AIF) as business income, thereby denying tax exemption under Section 10(23FBA) read with Section 115UB… Read More »

Elon Musk and co may relish march of the robots but there must be AI boundaries in the workplace

By | June 15, 2026
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Elon Musk and co may relish march of the robots but there must be AI boundaries in the workplace Elon Musk and co may relish march of the robots but there must be AI boundaries in the workplace As technology advances quickly, firms should not lose sight of what qualities humans bring to jobs A… Read More »