Monthly Archives: June 2026

Reassessment notices served on an NRI’s PAN or passport address are valid, but ex-parte orders without actual notice violate natural justice. Issue Whether the reassessment proceedings and consequential recovery actions initiated against a Non-Resident Indian (NRI) assessee were valid when statutory notices were directed to the domestic address listed in her PAN and passport, but… Read More »

Corporate car and telephone disallowances for personal use are deleted absent changed business facts. Issue Whether the Tribunal was justified in sustaining a 1/6th disallowance of car and telephone expenses on the grounds of personal use by a corporate assessee, especially when identical disallowances were deleted in preceding assessment years and no striking change in… Read More »

Retrospective amendment justifies rectification of past Tribunal orders via revenue’s miscellaneous application. Issue Whether the Income Tax Appellate Tribunal is justified in entertaining a miscellaneous application to rectify its previously passed final order based on a subsequent legislative amendment to Section 80P(2)(a)(iii) that was enacted with retrospective effect. Facts The assessee is a cooperative society… Read More »

Reassessment for AY 2015-16 is invalid as the statutory limitation window expired beyond TOLA coverage. Issue Whether the reassessment proceedings initiated for Assessment Year 2015-16 were barred by limitation under Section 149 of the Income-tax Act, 1961, given that the relaxation provisions under the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act,… Read More »

Reopening of Assessment Year 2015-16 Quashed as Barred by Limitation Under TOLA Guidelines Issue Whether the reassessment proceedings initiated for Assessment Year 2015-16 are barred by limitation under Section 149 of the Income-tax Act, considering that the relaxation provisions of the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act (TOLA) apply only… Read More »

Verified banking channels and unverified stamp portal data invalidate unexplained property investment tax additions. Issue Section 69 (Unexplained Investments): Whether an addition made by the Assessing Officer for unexplained investment can be sustained if the assessee presents comprehensive banking, PPF, and cash flow records explaining the complete source of the transaction. Section 56(2)(x) (Income from… Read More »

Business compensation, actual cost overruns, and initial site expenses are fully deductible revenue expenditures. Issue Tiruvottiyur Project: Whether a mutual cancellation compensation of Rs. 21 crores paid by a real estate developer is a fully deductible revenue expenditure under Section 37(1) or if it constitutes a project inventory cost that must be proportionally deferred based… Read More »

CCIT cannot reject delay condonation solely for lacking called-for particulars if Section 80P eligibility exists. Issue Whether the Chief Commissioner of Income Tax (CCIT) was justified in rejecting the applications filed by Cooperative Societies for condonation of delay in filing their income tax returns under CBDT Circular Nos. 13/2023 and 14/2024, on the ground that… Read More »