Monthly Archives: July 2026

An allotment letter cannot substitute an agreement for sale, and joint property additions must be apportioned.

By | July 10, 2026
0 Comment

An allotment letter cannot substitute an agreement for sale, and joint property additions must be apportioned. Issue Whether a preliminary builder’s allotment letter can be treated as an “agreement fixing the amount of consideration” under the first proviso to section 56(2)(x)(b)(B) to substitute the registration date’s stamp duty value, and whether the entire difference between… Read More »

Delayed EPF and ESI contributions cannot be disallowed under section 143(1)(a) when the issue is highly debatable.

By | July 10, 2026
0 Comment

Delayed EPF and ESI contributions cannot be disallowed under section 143(1)(a) when the issue is highly debatable. Issue Whether the Assessing Officer is legally justified in making a prima facie disallowance of delayed employees’ EPF and ESI contributions under Section 143(1)(a) when the underlying legal issue was highly debatable and subject to divergent High Court… Read More »

Royalty and straight-line lease rent are allowed, while the warranty provision is remanded for scientific verification.

By | July 10, 2026
0 Comment

Royalty and straight-line lease rent are allowed, while the warranty provision is remanded for scientific verification. Issue Whether the tax authorities can determine the Arm’s Length Price (ALP) of intra-group technical services at nil despite documented commercial benefits, treat historically allowed monthly royalty payments as capital expenses, disallow Accounting Standard-19 straight-line lease rents as notional,… Read More »

Textile machinery replacement expenditure is remanded for fresh verification under Supreme Court repair guidelines.

By | July 10, 2026
0 Comment

Textile machinery replacement expenditure is remanded for fresh verification under Supreme Court repair guidelines. Issue Whether the expenditure incurred by a textile manufacturing company on replacing independent, sophisticated plant and machinery can be classified as a deductible revenue expenditure or “current repairs,” or if it must be treated as a capital expenditure. Facts The assessee… Read More »

Estimated circular trading commission is sustained, demonetization deposits are deleted, and standard business tax rates apply.

By | July 10, 2026
0 Comment

Estimated circular trading commission is sustained, demonetization deposits are deleted, and standard business tax rates apply. Estimated circular trading commission is sustained, demonetization deposits are deleted, and standard business tax rates apply. Issue Whether estimated commission additions on circular trading are sustainable without adjustments, whether demonetization cash deposits backed by documented prior withdrawals can be… Read More »

CIT(E) cannot reject trust registration renewal by re-agitating grounds already quashed by the Tribunal.

By | July 10, 2026
0 Comment

CIT(E) cannot reject trust registration renewal by re-agitating grounds already quashed by the Tribunal. CIT(E) cannot reject trust registration renewal by re-agitating grounds already quashed by the Tribunal. Issue Whether the Commissioner of Income-tax (Exemptions) [CIT(E)] is legally justified in rejecting an assessee’s application for renewal of charitable registration under section 12A(1)(ac)(ii) by reviving the… Read More »

Manual filing of Form 10 does not justify reassessment if already examined during scrutiny.

By | July 10, 2026
0 Comment

Manual filing of Form 10 does not justify reassessment if already examined during scrutiny. Issue Whether the Revenue department can validly initiate reassessment proceedings under Section 148 to disallow income accumulation solely because Form 10 was filed manually instead of electronically, in a case where the Assessing Officer had already thoroughly examined and accepted the… Read More »

Tax disputes decided in favor of the assessee-bank based on binding precedents and legal provisions.

By | July 10, 2026
0 Comment

Tax disputes decided in favor of the assessee-bank based on binding precedents and legal provisions. Issue Whether the various additions and disallowances made by the Assessing Officer—concerning bad debt provisions under section 36(1)(viia), unrealized foreign exchange gains, Corporate Social Responsibility (CSR) expenditure, depreciation rates on ATMs (60%) and leased assets, section 14A disallowances, investment depreciation… Read More »

Capital gains are taxable on the execution date of the registered sale agreement for the absolute owner.

By | July 10, 2026
0 Comment

Capital gains are taxable on the execution date of the registered sale agreement for the absolute owner. Issue Whether the long-term capital gains from the sale of an immovable property are taxable in the assessment year matching the execution date of a registered agreement to sell, or in the subsequent year when the full consideration… Read More »

Tax Exemption for Recognized Clearing Corporations Under Income-Tax Act

By | July 10, 2026
0 Comment

Tax Exemption for Recognized Clearing Corporations Under Income-Tax Act Tax Exemption for Recognized Clearing Corporations Under Income-Tax Act SECTION 11, READ WITH SCHEDULE III OF THE INCOME-TAX ACT, 2025 – INCOMES NOT INCLUDED IN TOTAL INCOME – RECOGNISED CLEARING CORPORATION NOTIFICATION S.O. 3684(E) [NO. 79 /2026 / F.NO.197/39/2018-ITA-I], DATED 7-7-2026 In exercise of the powers conferred… Read More »