Daily Archives: August 27, 2026

Reopening assessment on interest from co-operative banks constitutes impermissible change of opinion and is unsustainable.

By | August 27, 2026
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Reopening assessment on interest from co-operative banks constitutes impermissible change of opinion and is unsustainable. Issue Whether reopening an assessment under Section 148 based on the same material examined during scrutiny to disallow Section 80P(2)(d) deduction constitutes an invalid change of opinion. Whether interest income earned by a co-operative society from investments in co-operative banks… Read More »

Reassessment Initiated Solely Based on Audit Party Objections Without New Facts Is Invalid Change of Opinion

By | August 27, 2026
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Reassessment Initiated Solely Based on Audit Party Objections Without New Facts Is Invalid Change of Opinion Reassessment Initiated Solely Based on Audit Party Objections Without New Facts Is Invalid Change of Opinion Issue Whether reopening of assessment under Section 147 after four years based solely on an audit party objection, without any new tangible material… Read More »

Lack of formal trust deed cannot justify refusing Section 12AB registration when genuine charitable activities exist

By | August 27, 2026
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Lack of formal trust deed cannot justify refusing Section 12AB registration when genuine charitable activities exist Lack of formal trust deed cannot justify refusing Section 12AB registration when genuine charitable activities exist Issue Whether the absence of a formal trust deed constitutes a valid ground for refusing renewal of registration under Section 12AB and approval… Read More »

Disallowance of depreciation on opening WDV of goodwill and vendor compliance expenses deleted in assessee’s favour.

By | August 27, 2026
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Disallowance of depreciation on opening WDV of goodwill and vendor compliance expenses deleted in assessee’s favour. Issue Whether the Assessing Officer was justified in re-examining and disallowing depreciation on the opening WDV of goodwill by treating its actual cost as nil, despite the issue being settled in the year of amalgamation. Whether the disallowance of… Read More »

Reversal of Unbilled Revenue Offered to Tax and Non-Royalty Payments to Non-Residents Are Deductible

By | August 27, 2026
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Reversal of Unbilled Revenue Offered to Tax and Non-Royalty Payments to Non-Residents Are Deductible Reversal of Unbilled Revenue Offered to Tax and Non-Royalty Payments to Non-Residents Are Deductible Issue Whether the reversal/write-off of opening unbilled revenue that was already offered to tax in preceding assessment years is allowable as business expenditure under Section 37(1). Whether… Read More »

Acquisition of RIL shares through financially incapable RPPL constitutes a benami transaction, but freezing untainted shares is invalid.

By | August 27, 2026
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Acquisition of RIL shares through financially incapable RPPL constitutes a benami transaction, but freezing untainted shares is invalid. Acquisition of RIL shares through financially incapable RPPL constitutes a benami transaction, but freezing untainted shares is invalid. Issue Whether the acquisition of 10.43 lakh shares of RIL by RPPL using funds routed from promoter-linked entities constitutes… Read More »