Reopening under Section 148 is invalid if based on incorrect facts and non-existent transaction figures Reopening under Section 148 is invalid if based on incorrect facts and non-existent transaction figures Issue Whether an assessment reopening under Section 148 of the Income-tax Act, 1961 (Section 280 / Section 102 of the Income-tax Act, 2025) is legally… Read More »
Exemption applies to agricultural land sold beyond specified municipal limits, making capital gains non-taxable under Section 2(14). Issue Whether capital gains tax is applicable on the sale of agricultural land situated beyond the prescribed statutory distance from municipal boundaries under Section 2(14) of the Income-tax Act. Facts The assessee transferred a parcel of agricultural land… Read More »
Retrospective Immunity Under Section 40(a)(i) Second Proviso Applies to Payments Made to Indian Branch of Foreign Company Without TDS Retrospective Immunity Under Section 40(a)(i) Second Proviso Applies to Payments Made to Indian Branch of Foreign Company Without TDS Issue Whether the second proviso to Section 40(a)(i) of the Income-tax Act, 1961 (Section 35 of the… Read More »
ITAT Benchmark Rates by Currency-Specific Standards, Restricts Guarantee Adjustment, and Relieves Foreign Exchange Loss Disallowances ITAT Benchmark Rates by Currency-Specific Standards, Restricts Guarantee Adjustment, and Relieves Foreign Exchange Loss Disallowances Issue Whether interest on foreign currency loans to AEs should be benchmarked using currency-specific rates (LIBOR) rather than Indian SBI PLR. Whether corporate guarantees to… Read More »
ITAT Rules in Favor of Assessee on Transfer Pricing, Subsidies, and Section 32AC While Upholding Revenue’s Section 43B Disallowance ITAT Rules in Favor of Assessee on Transfer Pricing, Subsidies, and Section 32AC While Upholding Revenue’s Section 43B Disallowance Issue Whether internal CUP based on State distribution tariffs, capital subsidies exemption, Section 32AC deduction on CWIP,… Read More »
Addition made under Section 69A for cash deposits during demonetization, treatment of agricultural land sale as capital gain, and estimation of business income under Section 44AD held bad in law and deleted in favor of the assessee. Issue Whether cash deposits during demonetization can be treated as unexplained money under Section 69A when the assessee… Read More »