Daily Archives: July 23, 2026

Additions for Share Application Money and Unsecured Loans Deleted as Assessee Discharged Primary Onus

By | July 23, 2026
0 Comment

Additions for Share Application Money and Unsecured Loans Deleted as Assessee Discharged Primary Onus Issue Whether additions made under Section 68 towards share application money and unsecured loans are sustainable when the assessee produces complete documentary evidence establishing the identity, creditworthiness, and genuineness of the lenders/applicants, and where the “source of source” amendment does not… Read More »

No Addition Allowed Under Section 50C as DVO Valuation Difference Was Under Tolerance Limits

By | July 23, 2026
0 Comment

No Addition Allowed Under Section 50C as DVO Valuation Difference Was Under Tolerance Limits Issue Whether the addition made under Section 50C based on the Departmental Valuation Officer (DVO)’s valuation is sustainable when the difference between the actual sale consideration and the DVO’s valuation is less than 15%, and whether the CIT(A) erred in adopting… Read More »

Disallowances and Additions Based on Retracted Statements and Uncorroborated Third-Party Materials Are Impermissible

By | July 23, 2026
0 Comment

Disallowances and Additions Based on Retracted Statements and Uncorroborated Third-Party Materials Are Impermissible Issue Whether additions made towards consultancy charges, alleged unaccounted cash sales, cash salary payments, land purchase “on-money”, and unexplained expenditures/moneys can be sustained under Sections 37, 68, 69A, and 69C when based solely on retracted statements, WhatsApp chats, and third-party loose papers… Read More »

Unanswered Commission Claims and Excess Section 14A Disallowance Restricted While 60% UPS Depreciation Allowed

By | July 23, 2026
0 Comment

Unanswered Commission Claims and Excess Section 14A Disallowance Restricted While 60% UPS Depreciation Allowed Issue Whether commission/brokerage expenses can be allowed where the Assessing Officer (AO) failed to issue Section 133(6) notices, and conversely, whether expenses should be disallowed for parties who received notices but failed to reply. Whether Rule 8D for Section 14A disallowance… Read More »

Tribunal Upholds Major Transfer Pricing, Business Loss, and Tax Deductions for Assessee Steel Manufacturer

By | July 23, 2026
0 Comment

Tribunal Upholds Major Transfer Pricing, Business Loss, and Tax Deductions for Assessee Steel Manufacturer Tribunal Upholds Major Transfer Pricing, Business Loss, and Tax Deductions for Assessee Steel Manufacturer Issue Whether transfer pricing adjustments on AE loans/guarantees/captive power, deductions for bad debts/business losses/written-off capital liabilities, sales tax gains, and Section 14A/115JB adjustments were rightly decided in… Read More »

Ex-Gratia Exemption Under Section 10(10B) Rejection of Form 10AB for Selecting Incorrect Section 12A Clause Is Curable Procedural Defect

By | July 23, 2026
0 Comment

Ex-Gratia Exemption Under Section 10(10B) Rejection of Form 10AB for Selecting Incorrect Section 12A Clause Is Curable Procedural Defect Ex-Gratia Exemption Under Section 10(10B) Rejection of Form 10AB for Selecting Incorrect Section 12A Clause Is Curable Procedural Defect Issue Whether the rejection of a trust’s Form No. 10AB registration application solely due to selecting an… Read More »

Ex-Gratia Exemption Under Section 10(10B) Is Allowed as Capital Receipt for BSNL VRS-2019 Employees

By | July 23, 2026
0 Comment

Ex-Gratia Exemption Under Section 10(10B) Is Allowed as Capital Receipt for BSNL VRS-2019 Employees Issue Whether ex-gratia compensation received by BSNL employees under the BSNL Voluntary Retirement Scheme, 2019 (BSNL VRS-2019) constitutes capital receipt in the nature of ‘Retrenchment Compensation’ fully exempt under Section 10(10B) of the Income-tax Act, 1961, rather than being restricted to… Read More »

Disallowance of Demerged Losses Upheld while ESOP Expenses Allowed and Deferred Income Addition Deleted.

By | July 23, 2026
0 Comment

Disallowance of Demerged Losses Upheld while ESOP Expenses Allowed and Deferred Income Addition Deleted. Issue Whether, for Assessment Year 2015–16: The disallowance of prior period expenses without due verification requires remand to the Assessing Officer; ESOP discount expenses claimed upon actual option exercise are allowable business expenditure under Section 37(1); Accumulated business losses and unabsorbed… Read More »

Purchase of Property Jointly with Spouse Is Excluded From Benami Transactions, Validating Will Bequeathing Full Ownership.

By | July 23, 2026
0 Comment

Purchase of Property Jointly with Spouse Is Excluded From Benami Transactions, Validating Will Bequeathing Full Ownership. Purchase of Property Jointly with Spouse Is Excluded From Benami Transactions, Validating Will Bequeathing Full Ownership. Issue Whether property purchased jointly in the names of a father and mother under a sale deed qualifies as a benami transaction, and… Read More »

Assessment under the Black Money Act is void for a Resident Not Ordinarily Resident as foreign shares acquired out of non-taxable foreign income are non-assessable and incorrectly valued.

By | July 23, 2026
0 Comment

Assessment under the Black Money Act is void for a Resident Not Ordinarily Resident as foreign shares acquired out of non-taxable foreign income are non-assessable and incorrectly valued. Assessment under the Black Money Act is void for a Resident Not Ordinarily Resident as foreign shares acquired out of non-taxable foreign income are non-assessable and incorrectly… Read More »