Exemption under Section 11 cannot be claimed for the first time in Section 148 returns. Issue Whether a charitable trust that failed to file returns under Section 139 within the prescribed time can validly claim exemption under Sections 11 and 12 for the first time in a return filed in response to a reassessment notice… Read More »
Date of transfer determines capital gains accrual, preventing substitution of subsequent higher transaction pricing. Issue Whether an assessee is entitled to deduction under Section 10AA when deduction claims were disallowed by the Assessing Officer for non-compliance and lack of documentary evidence, but partly allowed by the CIT(A) without seeking a remand report or verifying submissions… Read More »
Date of share transfer determines capital gains accrual, preventing substitution of subsequent higher transaction pricing. Issue Whether the Assessing Officer was justified in treating two separate share transfers executed on different dates at different prices as a single composite transaction and substituting the higher subsequent price for the earlier transfer to assess capital gains. Facts… Read More »
The Punjab & Haryana High Court has declared Section 147A of the Income-tax Act, 1961 unconstitutional, striking down the provision inserted by the Finance Act, 2026, with retrospective effect from April 1, 2021. Core Issue & Legislative Intent: Multiple High Courts previously held that notices under Section 148 must be issued through the faceless random… Read More »