Daily Archives: July 9, 2026

Input tax credit denial for 2018-19 is unsustainable as returns were filed before the extended statutory cut-off.

By | July 9, 2026

Input tax credit denial for 2018-19 is unsustainable as returns were filed before the extended statutory cut-off. Issue Whether the tax department can legally deny Input Tax Credit (ITC) on the grounds of belated filing when the taxpayer furnished their monthly returns for December 2018 to March 2019 within the extended statutory cut-off date of… Read More »

Inedible mixed Pooja oil is classifiable under Heading 1518, attracting a 5% GST rate.

By | July 9, 2026

Inedible mixed Pooja oil is classifiable under Heading 1518, attracting a 5% GST rate. Issue Whether the proposed ‘Pooja oil’, an inedible mixture comprising 99% vegetable oils and 1% sesame oil, is classifiable under Heading 1518, thereby attracting a 5% GST rate, despite the product being labeled and marketed as non-edible. Facts The applicant is… Read More »

INCOME TAX CASE LAWS 07.07.2026

By | July 9, 2026

INCOME TAX CASE LAWS 07.07.2026 Relevant Act Section Case Law Title Citation Brief Summary Income-tax Act, 1961 Section 2(14) Sundaramahalingam Narayanan v. Income-tax Officer Click Here No capital gains are chargeable if the Revenue fails to prove that the agricultural land sold falls within a municipality covered by a valid notification under Section 2(14)(iii)(b). Income-tax… Read More »

Condonation of delay is justified when non-service of orders prevents timely filing of appeals.

By | July 9, 2026

Condonation of delay is justified when non-service of orders prevents timely filing of appeals. Issue Whether the Commissioner of Income-tax (Appeals) [CIT(A)] was legally justified in dismissing the assessee’s quantum and penalty appeals in limine (at the threshold) due to delays of 1,486 and 1,181 days, without evaluating the merits or providing an opportunity to… Read More »

Extended reassessment is invalid if the quantified escaped income is below fifty lakh rupees.

By | July 9, 2026

Extended reassessment is invalid if the quantified escaped income is below fifty lakh rupees. Issue Whether a reassessment notice issued under section 148 after the standard three-year limitation period is legally sustainable when the Assessing Officer’s own order quantifies the total alleged escaped income at Rs. 42.82 lakhs, which falls below the statutory threshold of… Read More »

An order under section 148A(b) cannot stand if the Assessing Officer fails to consider the assessee’s reply and supporting materials.

By | July 9, 2026

An order under section 148A(b) cannot stand if the Assessing Officer fails to consider the assessee’s reply and supporting materials. Issue Whether an order passed under section 148A(d) and the consequential reassessment notice issued under section 148 can be legally sustained when the Assessing Officer completely fails to consider the assessee’s detailed replies and supporting… Read More »

Unrecorded warranty receivables from an AE constitute an asset, validating extended reassessment and special audit.

By | July 9, 2026

Unrecorded warranty receivables from an AE constitute an asset, validating extended reassessment and special audit. Issue Whether unrecorded contractual receivables from an Associated Enterprise (AE) for warranty reimbursements constitute an “asset” under Section 153A, allowing the extended 10-year reassessment notice window under Section 149(1)(b). Whether an extended reassessment notice can be sustained if the recorded… Read More »

Cash deposits from agricultural land sale require factual verification and matter is remanded for de novo adjudication.

By | July 9, 2026

Cash deposits from agricultural land sale require factual verification and matter is remanded for de novo adjudication. Issue Whether the addition of cash deposits worth Rs. 10.05 lakhs as unexplained money under section 69A of the Income-tax Act, 1961 is legally sustainable when the assessee submits documentary evidence proving the funds arose from an exempt… Read More »

On-money from an incomplete project cannot be taxed under the project completion method via revisionary powers.

By | July 9, 2026

On-money from an incomplete project cannot be taxed under the project completion method via revisionary powers. Issue Whether the Principal Commissioner of Income-tax (PCIT) can validly invoke revisionary powers under section 263 to tax an on-money receipt of Rs. 7.96 crore in the current assessment year, when the assessee follows the undisputed project completion method… Read More »

Sale proceeds from undisputed prior-year unlisted investments cannot be treated as unexplained cash credits.

By | July 9, 2026

Sale proceeds from undisputed prior-year unlisted investments cannot be treated as unexplained cash credits. Issue Whether the sale proceeds from the disposal of unlisted equity investments, which originated in unchecked prior years, can be treated as unexplained cash credits under section 68, and whether an ad hoc addition for commission expenses can be made under… Read More »