Monthly Archives: August 2026

Four-Year Delay In Recording Satisfaction Note Invaluates Search Proceedings Under Section 153C

By | August 19, 2026
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Four-Year Delay In Recording Satisfaction Note Invaluates Search Proceedings Under Section 153C Four-Year Delay In Recording Satisfaction Note Invaluates Search Proceedings Under Section 153C Issue Whether initiation of search assessment proceedings under Section 153C against a third party is legally sustainable when there is an unexplained delay of over four years between the search execution… Read More »

Retrospective Insertion Of Section 147A Validates Jurisdiction Of JAO To Initiate And Conduct Reassessment Proceedings

By | August 19, 2026
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Retrospective Insertion Of Section 147A Validates Jurisdiction Of JAO To Initiate And Conduct Reassessment Proceedings Retrospective Insertion Of Section 147A Validates Jurisdiction Of JAO To Initiate And Conduct Reassessment Proceedings Issue Whether, in view of the retrospective insertion of Section 147A by the Finance Act, 2026 with effect from April 1, 2021, the Jurisdictional Assessing… Read More »

Technical Glitch In Delay Filing Form 10-IC Entitles Domestic Company To Concessional Tax Rate Under Section 115BAA

By | August 19, 2026
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Technical Glitch In Delay Filing Form 10-IC Entitles Domestic Company To Concessional Tax Rate Under Section 115BAA Issue Whether a domestic company is entitled to the concessional rate of tax under Section 115BAA when Form 10-IC and the return of income were filed after the due date due to technical glitches on the e-filing portal,… Read More »

SLP Dismissed As Reassessment Cannot Be Initiated Based Solely On Bank Debit-Credit Entries Without Evidence Of Escaped Income

By | August 19, 2026
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SLP Dismissed As Reassessment Cannot Be Initiated Based Solely On Bank Debit-Credit Entries Without Evidence Of Escaped Income Issue Whether reassessment under Section 148 read with Section 148A can be sustained when initiated solely on high-value bank debit and credit entries, despite the assessee explaining all banking transactions with complete documentary evidence and no cash… Read More »

Reassessment Cannot Be Initiated On Mere Suspicion Without Information Indicating Escapement Of Recorded Business Income

By | August 19, 2026
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Reassessment Cannot Be Initiated On Mere Suspicion Without Information Indicating Escapement Of Recorded Business Income Reassessment Cannot Be Initiated On Mere Suspicion Without Information Indicating Escapement Of Recorded Business Income Issue Whether reassessment under Section 148 can be initiated on the basis of a Suspicious Transaction Report (STR) flagging high-value transactions, when all transactions are… Read More »

Notice Under Section 143(2) Is Not Mandatory In Reassessment Proceedings As Section 147/148 Forms A Separate Code

By | August 19, 2026
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Notice Under Section 143(2) Is Not Mandatory In Reassessment Proceedings As Section 147/148 Forms A Separate Code Issue Whether non-issuance and non-service of a notice under Section 143(2) during reassessment proceedings under Sections 147/148 invalidates the reassessment order, or whether Section 147/148 acts as a separate code for assessing escaped income where a Section 143(2)… Read More »

Fair Market Value Of JDA Built-Up Area Determines Consideration; Disallowance Of Interest Expenditure Is Impermissible With Sufficient Interest-Free Funds

By | August 19, 2026
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Fair Market Value Of JDA Built-Up Area Determines Consideration; Disallowance Of Interest Expenditure Is Impermissible With Sufficient Interest-Free Funds Issue Whether, for computing business income under a Joint Development Agreement (JDA) where land converted into stock-in-trade is exchanged for constructed area, the “full value of consideration” is to be determined based on the Fair Market… Read More »

Cooperative Society Entitled To Section 80P Deduction And Full Additional Depreciation On Milk Processing Equipment

By | August 19, 2026
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Cooperative Society Entitled To Section 80P Deduction And Full Additional Depreciation On Milk Processing Equipment Issue Whether a cooperative society engaged in milk procurement is entitled to deduction under Section 80P(2)(d) on interest/dividend income earned from investments in other cooperative entities. Whether milk cans and related equipment qualify as plant and machinery eligible for additional… Read More »

Depreciation Is Allowable On Entire Contractual Cost Of IPL Franchise And TP Adjustments Require Mandatory TPO Reference

By | August 19, 2026
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Depreciation Is Allowable On Entire Contractual Cost Of IPL Franchise And TP Adjustments Require Mandatory TPO Reference Issue Whether “actual cost” under Section 43(1) for claiming depreciation on intangible assets (IPL franchise rights) means the entire contractual consideration or is limited to the actual instalments paid during the relevant year. Whether the Assessing Officer /… Read More »

Expenditure On Minor Repairs, Consumables, And Written-Off Vendor Advances Allowable As Business Revenue Deduction

By | August 19, 2026
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Expenditure On Minor Repairs, Consumables, And Written-Off Vendor Advances Allowable As Business Revenue Deduction Issue Whether expenditure incurred on slotted angles, racks, and modules for existing plant maintenance constitutes revenue expenditure under Section 37(1) or capital expenditure. Whether housekeeping and consumable expenses supported by internal journal entries and shop-floor issue logs with underlying purchase invoices… Read More »