Reassessment order must be quashed if the Assessing Officer fails to consider the assessee’s replies Reassessment order must be quashed if the Assessing Officer fails to consider the assessee’s replies Issue Whether an order passed under Section 148A(3) and a consequential reassessment notice under Section 148 are legally sustainable if the Assessing Officer fails to… Read More »
Foreign exchange gains are operating income, and expense allocation must follow gross profit margins Issue Whether the Transfer Pricing Officer (TPO) is legally justified in treating business-related foreign exchange gains as non-operating income, modifying common expense allocations from gross profit to turnover basis, and eliminating comparables without persistent losses under the Transactional Net Margin Method… Read More »
Additions for notional interest, ad-hoc expenses, and trade payables are invalid after favorable remand report Issue Whether the Assessing Officer can sustainably maintain tax additions for notional interest on subsidiary loans, ad-hoc expense disallowances, and unexplained trade payables when the revenue’s own remand report subsequently accepts the assessee’s explanations without any adverse remarks. Facts The… Read More »
One-time settlement to contractors is fully deductible under Section 37 as revenue business expenditure Issue Whether a one-time settlement paid to contractors during business restructuring can be restricted to a one-fifth deduction under Section 35DDA parity, and whether Section 14A disallowances and DDT treaty rate claims can be finalized without proper lower authority verification or… Read More »
CIT(E) cannot reject a trust’s renewal application over a technical selection mistake in Form 10AB Issue Whether the CIT(E) is legally justified in rejecting a charitable trust’s renewal application under Section 12AB simply because the trust inadvertently selected the incorrect statutory clause on the electronic form. Facts The Assessee: A charitable institution that already held… Read More »
Foreign bank operations win relief on disallowances under Section 14A, 37, and 115JA regimes Issue Whether the various additions and disallowances made by the Assessing Officer concerning Section 14A exempt income expenses, broken period interest on stock-in-trade, MAT applicability to banking companies, gross taxation of foreign currency loans, intra-entity transactions with the Head Office, taxability… Read More »
Disallowances under Section 14A, 37, and 115JA are deleted for foreign banks on multiple issues Issue Whether the various additions and disallowances made by the Assessing Officer concerning Section 14A exempt income expenses, broken period interest on stock-in-trade, MAT applicability to banking companies, gross taxation of foreign currency loans, intra-entity transactions with the Head Office,… Read More »
CIT(E) Cannot Cancel Hospital’s Trust Registration Retrospectively Over Self-Determined Non-Tax Violations and Premium Infrastructure Issue Whether the CIT(E) is legally justified in retrospectively cancelling and refusing the renewal of a public charitable hospital’s tax registration under Section 12AB and Section 80G by self-adjudicating alleged compliance failures under the Maharashtra Public Trusts Act (Indigent Patient Fund… Read More »
Notification regarding Employees Provident Funds (EPF) Scheme, 2026 The Gazette of India CG-DL-E-01072026-273957 EXTRAORDINARY PART II—Section 3—Sub-section (i) PUBLISHED BY AUTHORITY No. 473] NEW DELHI, MONDAY, JUNE 29, 2026/ ASHADHA 8, 1948 MINISTRY OF LABOUR AND EMPLOYMENT NOTIFICATION New Delhi, the 29th June, 2026 G.S.R. 525(E).— In exercise of the powers conferred by clause (a)… Read More »
Notification regarding extension of the Punjab Right to Business Act, 2020 (1 of 2020) to UT of Chandigarh Notification regarding extension of the Punjab Right to Business Act, 2020 (1 of 2020) to UT of Chandigarh The Gazette of India CG-DL-E-03072026-274038 EXTRAORDINARY PART II—Section 3—Sub-section (ii) PUBLISHED BY AUTHORITY No. 3469] NEW DELHI, THURSDAY, JULY… Read More »