Alleged On-Money Requires Specific Ownership Proof, While WhatsApp Evidence Validates Reduced Section 69A Addition Issue Issue 1 (Section 69 / Section 103): Whether alleged “on-money” recorded in seized electronic files for property purchases can be added as unexplained investment under Section 69 in the hands of an individual whose trade name was listed as a… Read More »
Assessment Remanded to Re-examine Capital Gains Documents Pertaining to Sold Immovable Properties Assessment Remanded to Re-examine Capital Gains Documents Pertaining to Sold Immovable Properties Issue Whether an assessment addition under Section 69 of the Income-tax Act, 1961 (Section 103 of the Income-tax Act, 2025) for unexplained investment/undisclosed capital gains should be restored to the Assessing… Read More »
Tax Addition Under Section 68 Unjustified for Demonetised Cash Repayments and Related Interest Income Issue Whether cash repayments of existing loans received in Specified Bank Notes (SBNs) by a micro-finance NBFC, and the corresponding interest income already credited to the Profit & Loss account, can be treated as unexplained cash credits under Section 68 of… Read More »
Reopening under Section 148 is invalid when premised on change of opinion without new tangible material Reopening under Section 148 is invalid when premised on change of opinion without new tangible material Issue Whether an assessment reopening under Section 148 of the Income-tax Act, 1961 (Section 280 / Section 102 of the Income-tax Act, 2025)… Read More »
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 »