Foreign remittances with a verified banking trail cannot be taxed as unexplained investments. Issue Whether the Assessing Officer was legally justified in treating the investment in a residential property as an unexplained investment under Section 69 of the Income-tax Act, 1961, when the assessee established a clear banking trail of foreign inward remittances from her… Read More »
Inter-trust transfers out of accumulated funds are strictly taxable as deemed income regardless of project nomenclature. Issue Whether payments made out of accumulated income under Section 11(2) by a charitable trust to other Section 12AA-registered institutions for project implementation are hit by the restriction in Section 11(3)(d) and taxable as deemed income. Facts Income Accumulation:… Read More »
Inter-trust transfers out of accumulated funds are strictly taxable as deemed income regardless of project nomenclature. Issue Whether payments made out of accumulated income under Section 11(2) by a charitable trust to other Section 12AA-registered institutions for project implementation are hit by the restriction in Section 11(3)(d) and taxable as deemed income. Facts Income Accumulation:… Read More »
Trust payment from accumulated income to another registered trust is taxable as deemed income. Issue Whether the payment of funds out of accumulated income under Section 11(2) by a charitable trust to other institutions registered under Section 12AA—under the nomenclature of project implementation and services—violates Section 11(3)(d) and must be treated as the taxable deemed… Read More »
State-governed charitable trust is entitled to exemption as fund transfer for hazard mitigation equipment does not violate section 13. Issue Whether the appellant-trust, formed by the State Government for disaster mitigation, is entitled to tax exemption under Section 11 when its interest income was spent on purchasing high-end hazard mitigation computing equipment in the name… Read More »
Non-resident bank wins on inter-branch transactions, interest, exemptions, and key business expense deductions. Issue Whether various additions and disallowances made by the Assessing Officer concerning inter-branch transactions, overseas third-party bank interest, expense allocations ($§14\text{A}$), write-backs, broken period interest, club fees, interest on processing refunds ($§234\text{B}$), year-end forex revaluations, and CRR/SLR shortfalls are legally sustainable under… Read More »
Consideration received for transferring property development rights is taxable exclusively under Capital Gains. Issue Whether development rights in an immovable property constitute a “capital asset” under Section 2(14) of the Income-tax Act, making the contractual consideration received for their transfer taxable under the head “Capital Gains” rather than “Income from Other Sources.” Facts The Agreement:… Read More »
Consideration received for transferring development rights is taxable as capital gains, not other sources. Issue Whether development rights in an immovable property constitute a “capital asset” under Section 2(14), making the contractual consideration received for their transfer taxable under the head “Capital Gains” rather than “Income from Other Sources.” Facts Agreement: The assessee, along with… Read More »
Condonation of Delay for Filing Electronic Form 10AB Under Section 80G(5) CONDONATION OF DELAY IN FILING FORM NO. 10AB ELECTRONICALLY FOR APPROVAL UNDER CLAUSE (ii) OF THE FIRST PROVISO TO SECTION 80G(5) OF THE INCOME-TAX ACT, 1961 CIRCULAR NO. 6/2026 [F. NO. 300176/3/2026-ITA-I], DATED 2-7-2026 Section 80G of the Income-tax Act, 1961 (“the Act”) provides for deduction in… Read More »
Income Tax Exemption Notification for Statutory Bodies and Authorities Under Section 10(46) SECTION 10(46) OF THE INCOME-TAX ACT, 1961, READ WITH SECTION 536 OF THE INCOME-TAX ACT, 2025 – EXEMPTIONS – STATUTORY BODY/AUTHORITY/BOARD/COMMISSION – NOTIFIED BODY OR AUTHORITY NOTIFICATION S.O. 3596(E) [NO. 73 /2026/F. NO. 300196/32/2021-ITA-I], DATED 2-7-2026 Whereas, section 10 (46) of the Income-tax Act, 1961 (43… Read More »