Monthly Archives: August 2026

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 »

Depreciation Claim Allowed for Vehicle Paid For and Used by Company Despite Registration in Director’s Name

By | August 18, 2026
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Depreciation Claim Allowed for Vehicle Paid For and Used by Company Despite Registration in Director’s Name Issue Whether a company is entitled to claim depreciation under Section 32 of the Income-tax Act, 1961 on a vehicle purchased and used for its business, when the funds were paid by the company but the registration stands in… Read More »

Concluded APA Implementation Upheld for Transfer Pricing and Disallowances Deleted Following Past Judicial Precedents

By | August 18, 2026
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Concluded APA Implementation Upheld for Transfer Pricing and Disallowances Deleted Following Past Judicial Precedents Issue Whether transfer pricing adjustments under Chapter X (AMP expenses, royalty, HQ expenses, service warranty) must be recomputed in terms of a concluded Advance Pricing Agreement (APA) under Section 92CC covering the relevant assessment and rollback years. Whether disallowances of expatriate… Read More »

Renewal under Sections 12AB and 80G Cannot Be Rejected Based on Pre-2021 Search Materials

By | August 18, 2026
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Renewal under Sections 12AB and 80G Cannot Be Rejected Based on Pre-2021 Search Materials Issue Whether the Principal Commissioner can reject an application for renewal of registration under Section 12AB and approval under Section 80G by relying on past search/investigation materials prior to 01-04-2021, rather than confining the enquiry to the activities and compliance of… Read More »

How Gemini plans such detailed vacation itineraries for you

By | August 17, 2026
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How Gemini plans such detailed vacation itineraries for you How Gemini plans such detailed vacation itineraries for you Planning a trip? Gemini handles the details — juggling existing plans, personal preferences and more to craft custom travel itineraries. Planning a trip can feel like a second job. Between hunting down flight confirmations, mapping distances between… Read More »

GST CASE LAW 16.07.2025

By | August 17, 2026
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GST CASE LAW 16.07.2025 Section Case Law Title Brief Summary Citation Relevant Act Manpower Service / Exemption (Sl. No. 3, Notfn 12/2017) Webel Support Multipurpose Service Co Operative Society Ltd., In re Pure labour services provided as a sub-contractor to a State Government Company for a government project do not qualify for exemption under Sl.… Read More »