Daily Archives: July 4, 2026

Section 80-IB deduction does not reduce profits for computing Section 80HHC deduction; matter remanded.

By | July 4, 2026

Section 80-IB deduction does not reduce profits for computing Section 80HHC deduction; matter remanded. Issue Whether the restriction under Section 80-IA(9) requires the deduction under Section 80-IB to be reduced from business profits before computing the Section 80HHC deduction, or if it merely restricts the final allowability of the total deductions. Facts For the assessment… Read More »

Deduction under Section 80-IB excludes DEPB/duty drawback; Section 80-IA vs 80-HHC computation issue is remanded.

By | July 4, 2026

Deduction under Section 80-IB excludes DEPB/duty drawback; Section 80-IA vs 80-HHC computation issue is remanded. Issue Issue 1: Whether the relief under Section 80-IA must be deducted from business profits before computing the export deduction under Section 80-HHC, and whether this needs to be re-evaluated based on recent Supreme Court precedent. Issue 2: Whether incentives… Read More »

Long-term capital losses can be set off against capital gains arising from depreciable assets.

By | July 4, 2026

Long-term capital losses can be set off against capital gains arising from depreciable assets. Issue Whether the deeming fiction under section 50, which treats gains from depreciable assets as short-term capital gains, converts the underlying long-term asset into a short-term asset, thereby barring the set-off of current year and brought forward long-term capital losses under… Read More »

Reassessment order is invalid as a mere change of opinion on already examined cash deposits.

By | July 4, 2026

Reassessment order is invalid as a mere change of opinion on already examined cash deposits. Issue Whether the reassessment proceedings and subsequent addition under section 69A of the Income-tax Act, 1961 were valid when the specific issue of cash deposits had already been examined and accepted during the original assessment under section 143(3). Facts For… Read More »

Cash deposits are fully explained by a co-owner’s accepted advance and verified bank withdrawals

By | July 4, 2026

Cash deposits are fully explained by a co-owner’s accepted advance and verified bank withdrawals Issue Whether a Section 69A addition for unexplained cash deposits totaling ₹48 lakhs can be sustained when a co-owner’s tax proceedings have already validated the primary source of the funds and the remaining deposits are backed by documented bank withdrawals. Facts… Read More »