Section 148 notice issued by a Jurisdictional Assessing Officer instead of the NFAC is legally invalid. Issue Whether a notice issued under Section 148 by a Jurisdictional Assessing Officer (JAO), instead of the National Faceless Assessment Centre (NFAC) as mandated by the CBDT Notification dated 29-3-2022, is valid and sustainable in law. Facts The Assessee… Read More »
Reassessment is validly initiated under Section 143(1), but interest on earmarked funds reduces pre-operative expenses. Issue Whether the Assessing Officer can validly reopen an assessment under Section 147 when the original return was only processed under Section 143(1) and no formal scrutiny assessment order was passed. Whether the Income Tax Appellate Tribunal has the jurisdiction… Read More »
Suppressed Sale Consideration Must Be Taxed As Capital Gains, Not As Unexplained Money. Issue Whether an undisclosed receipt toward a property sale, found during a third-party search, must be taxed as part of the full value of consideration under Capital Gains in the year of transfer, or if it can be treated as unexplained money… Read More »
No penalty for under-reporting is leviable on retrospective disallowance of a bona fide education cess claim. Issue Whether a penalty for under-reporting income under Section 270A can be legally sustained when the deduction claimed (Education Cess) was based on prevalent judicial precedents but was subsequently disallowed by a retrospective amendment under the Finance Act, 2022.… Read More »
Policy servicing fees to aggregators are allowable deductions, and Section 14A disallowance is inapplicable to insurance businesses. Issue Whether payments made by a general insurance company to aggregators/intermediaries for policy servicing and support activities can be disallowed under Explanation 1 to Section 37(1) as an expense prohibited by law, in the absence of any penal… Read More »
Post-Act suits cannot enforce rights in pre-existing benami properties, which face government acquisition. Issue Whether a plaintiff can maintain a suit to enforce rights or protect possession over a property purchased benami before 1988 if the suit is filed after the Benami Act’s commencement. Whether the original sellers or their legal heirs can assert continued… Read More »
Assessment Under Section 153C Requires Incriminating Material; Single Agricultural Land Sale Is Exempt Capital Asset. Issue Whether the Revenue can validly initiate proceedings and complete an assessment under Section 153C read with Section 153A without satisfying that the seized documents are of an “incriminating” nature and legally linkable to the relevant Assessment Year. Whether a… Read More »
How Gemini is speaking the language of Southeast Asia How Gemini is speaking the language of Southeast Asia Active users on the Gemini app in Southeast Asia have more than doubled in the last year. Here is a look at how the region is using the chatbot in their daily life. People are making Gemini… Read More »
AI SEO: Writing That’s Specific May Get Cited More AI SEO: Writing That’s Specific May Get Cited More AI SEO that prioritizes content that is specific may be a key to getting cited by AI search engines like Anthropic’s Claude. Someone posted on social media about their experience writing deep and insightful articles last year… Read More »
Made to Create | Scott Hansen is Tycho | Adobe Made to Create | Scott Hansen is Tycho | Adobe Scott Hansen always loved music, but never imagined he could be the one creating it. And while he dreamed of making art, he struggled to translate the ideas in his head until he discovered Photoshop… Read More »