Daily Archives: August 18, 2026

Addition for House Property Fixed at Disclosed Value, FDR Addition Restricted to Investment Amount, and Telescoping Denied

By | August 18, 2026
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Addition for House Property Fixed at Disclosed Value, FDR Addition Restricted to Investment Amount, and Telescoping Denied Issue Whether the Tribunal was justified in estimating house property value at ₹85 lakhs over the disclosed ₹70 lakhs, denying telescoping benefit for unaccounted cash, and taxing FDR maturity values instead of actual investment amounts during block assessment.… Read More »

Cash Sales Credited to Profit and Loss Account Cannot Be Added Again as Section 68 Cash Credits

By | August 18, 2026
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Cash Sales Credited to Profit and Loss Account Cannot Be Added Again as Section 68 Cash Credits Issue Whether cash received from sales and already credited to the Profit and Loss Account as part of business turnover can be added again as unexplained cash credit under Section 68 of the Income-tax Act, 1961. Facts Original… Read More »

Unsubstantiated Additions Under Sections 68 and 69C for Repaid Unsecured Loans Deleted

By | August 18, 2026
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Unsubstantiated Additions Under Sections 68 and 69C for Repaid Unsecured Loans Deleted Unsubstantiated Additions Under Sections 68 and 69C for Repaid Unsecured Loans Deleted Issue Whether additions made towards unexplained cash credits under Section 68 and alleged commission expenses under Section 69C can be sustained when the unsecured loans were received via banking channels, bore… Read More »

Reassessment Order Based on Mere Suspicion Without Materials Countering Assessee’s Documented Explanations Quashed

By | August 18, 2026
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Reassessment Order Based on Mere Suspicion Without Materials Countering Assessee’s Documented Explanations Quashed Issue Whether a reassessment notice under Section 148 and order under Section 148A(3) based on Suspicious Transaction Reports (STRs) can be sustained when the Assessing Officer fails to substantively deal with the assessee’s supporting documents and possesses no material indicating bogus transactions… Read More »

No Movement of Shares in DEMAT Means No Transfer or Cash Addition; Write-Off Is Not Unexplained Expenditure

By | August 18, 2026
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No Movement of Shares in DEMAT Means No Transfer or Cash Addition; Write-Off Is Not Unexplained Expenditure Issue Whether an addition under Section 68 can be sustained as unexplained cash credit on a notional share transaction where no actual transfer of shares occurred in the DEMAT account, and whether the validity of such transaction warrants… Read More »

Addition Under Section 68 Deleted as Penny Stock Finding Lacked Independent Enquiry and Transacted via Bank and Demat

By | August 18, 2026
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Addition Under Section 68 Deleted as Penny Stock Finding Lacked Independent Enquiry and Transacted via Bank and Demat Issue Whether an addition under Section 68 treating long-term capital gains from share transactions as non-genuine penny stock gains can be sustained when based solely on Investigation Wing reports without independent verification by the Assessing Officer. Facts… Read More »

Gain From Repurchase of Unexercised Vested Stock Options Is Taxable as Capital Gains, Not Salary Perquisite

By | August 18, 2026
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Gain From Repurchase of Unexercised Vested Stock Options Is Taxable as Capital Gains, Not Salary Perquisite Issue Whether the consideration received by an employee upon the repurchase of vested stock options—which were never exercised into shares—is taxable as “Capital Gains” under Section 45 or as a salary “Perquisite” under Section 17(2) of the Income-tax Act,… Read More »

Market Research Expenditure Incurred to Understand Consumer Behaviour and Improve Sales Strategy Constitutes Allowable Revenue Expenditure

By | August 18, 2026
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Market Research Expenditure Incurred to Understand Consumer Behaviour and Improve Sales Strategy Constitutes Allowable Revenue Expenditure Issue Whether market research expenditure incurred in the normal course of business to evaluate consumer behaviour, improve marketing strategy, and drive sales constitutes allowable revenue expenditure under Section 37(1) of the Income-tax Act, 1961. Facts Expenditure Claimed: During Assessment… Read More »

Interest-Free Loans to AE Attract Transfer Pricing Adjustments While Ongoing Marketing Costs Remain Revenue Expenditure

By | August 18, 2026
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Interest-Free Loans to AE Attract Transfer Pricing Adjustments While Ongoing Marketing Costs Remain Revenue Expenditure Interest-Free Loans to AE Attract Transfer Pricing Adjustments While Ongoing Marketing Costs Remain Revenue Expenditure Issue Whether advancing interest-free funds to an Associated Enterprise (AE) constitutes an international transaction requiring transfer pricing benchmarking, irrespective of the availability of interest-free own… Read More »

Recharacterisation of CCDs as Equity Set Aside and Bad Debt Write-Off Allowed

By | August 18, 2026
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Recharacterisation of CCDs as Equity Set Aside and Bad Debt Write-Off Allowed Issue Whether the Transfer Pricing Officer (TPO) can re-characterise Compulsorily Convertible Debentures (CCDs) as equity instruments prior to conversion to determine the Arm’s Length Price (ALP) of interest at Nil under the ‘Other Method’ instead of evaluating the CUP Method. Whether bad debts… Read More »