Remand Required to Verify Dual Salary Ledgers and Cash Payment Claims Under Section 40A(3) Remand Required to Verify Dual Salary Ledgers and Cash Payment Claims Under Section 40A(3) Issue Whether the disallowance of salary expenditure under Section 40A(3) for cash payments exceeding the prescribed limit is sustainable without complete verification of the assessee’s voluminous expense… Read More »
Processing Return Under Section 143(1) Post Section 143(2) Notice Is Valid and ESOP Cross-Charge Expenses Are Allowable Business Deductions Processing Return Under Section 143(1) Post Section 143(2) Notice Is Valid and ESOP Cross-Charge Expenses Are Allowable Business Deductions Issue Validity of Section 143(1) Processing Post Section 143(2) Notice & Doctrine of Merger: Whether processing a… Read More »
No TDS Applies to Cost Reimbursements Where Tax Was Deducted at Source Initially No TDS Applies to Cost Reimbursements Where Tax Was Deducted at Source Initially Issues TDS on Reimbursement of Apportioned Expenses: Whether Section 40(a)(ia) applies to payments made by an assessee to an association towards reimbursement of its share of legal expenses where… Read More »
Extraordinary COVID-19 Overhead Costs Must Be Excluded as Non-Operating and TP Adjustments Must Be Restricted to AE Transactions Issues Exclusion of Extraordinary COVID-19 Fixed Overheads: Whether extraordinary fixed overhead costs (salaries, depreciation, etc.) incurred during COVID-19 lockdown without generating operating revenue should be treated as non-operating expenses and excluded from the Profit Level Indicator (PLI)… Read More »
Supreme Court Dismisses Revenue’s SLP as Withdrawn, Upholding That Section 14A Requires Actual Exempt Income Supreme Court Dismisses Revenue’s SLP as Withdrawn, Upholding That Section 14A Requires Actual Exempt Income Issue Whether Section 14A of the Income-tax Act, 1961 (corresponding to Section 14 of the Income-tax Act, 2025) can be invoked to disallow expenditure when… Read More »
Supreme Court Dismisses Revenue SLP Affirming High Court Ruling Favouring Insurance Assessee Across Issues Supreme Court Dismisses Revenue SLP Affirming High Court Ruling Favouring Insurance Assessee Across Issues Issues Applicability of Disallowance Under Section 14A: Whether Section 14A applies to the computation of profits and gains of general insurance businesses under Section 44 read with… Read More »