Daily Archives: September 28, 2026

Non-Supply of Dissemination Reports Under Section 148A Vitiates Proceedings and Justifies Quashing Reassessment

By | September 28, 2026
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Non-Supply of Dissemination Reports Under Section 148A Vitiates Proceedings and Justifies Quashing Reassessment Issue Whether the non-disclosure of foundational dissemination reports at the stage of notice under Section 148A(1) constitutes a fatal jurisdictional defect that invalidates the reassessment order passed under Section 148A(3) and the consequential notice issued under Section 148. Facts Background: The assessee,… Read More »

Assignment Considerations Are Capital Receipts Not Taxable Under Other Sources, Interest Expenditure Requires Direct Nexus

By | September 28, 2026
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Assignment Considerations Are Capital Receipts Not Taxable Under Other Sources, Interest Expenditure Requires Direct Nexus Issue Whether consideration received under a Deed of Assignment relinquishing rights/claims in a pending property suit is a capital receipt rather than revenue taxable under ‘Income from other sources’ under Section 56. Whether expenditure claimed against interest income under Section… Read More »

ITAT Directs AO to Verify Section 54F Exemption Claim Raised for First Time Before DRP

By | September 28, 2026
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ITAT Directs AO to Verify Section 54F Exemption Claim Raised for First Time Before DRP ITAT Directs AO to Verify Section 54F Exemption Claim Raised for First Time Before DRP Issue Whether an additional claim for exemption under Section 54F, raised for the first time before the Dispute Resolution Panel (DRP), should be admitted and… Read More »

Rule 87 Inapplicable for PF Disallowance, Remanded for 43B Verification; Ad-hoc Expenses Disallowance Upheld

By | September 28, 2026
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Rule 87 Inapplicable for PF Disallowance, Remanded for 43B Verification; Ad-hoc Expenses Disallowance Upheld Issue Rule 87 & PF Disallowance: Whether the Assessing Officer was justified in invoking Rule 87 to disallow employer’s Provident Fund (PF) contributions exceeding 27% of salaries, and whether actual payment under Section 43B required verification. Ad-hoc Expense Disallowance: Whether a… Read More »

Tribunal Rules in Favor of Scheduled Bank on Bad Debts, Broken Period Interest, and Section 80M Deductions

By | September 28, 2026
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Tribunal Rules in Favor of Scheduled Bank on Bad Debts, Broken Period Interest, and Section 80M Deductions Issue Section 80M & Rule 8D Disallowance: Whether expenditure can be estimated and attributed under Rule 8D for Section 80M / 14A computations when the assessee-bank possesses sufficient interest-free own funds to cover investments. Bad Debts Write-off: Whether… Read More »

Provisional Attachment Order under PBPT Act Quashed due to Approval Preceding Section 24 Notice

By | September 28, 2026
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Provisional Attachment Order under PBPT Act Quashed due to Approval Preceding Section 24 Notice Issue Whether a Provisional Attachment Order and its subsequent confirmation under Section 24 of the Prohibition of Benami Property Transactions Act, 1988 are valid when the approval of the Approving Authority under Section 24(3) was obtained prior to issuing the foundational… Read More »

Fresh Disallowance Under Section 14A Involving Debatable Exercise Cannot Be Made Under Rectification Proceedings

By | September 28, 2026
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Fresh Disallowance Under Section 14A Involving Debatable Exercise Cannot Be Made Under Rectification Proceedings Issue Whether the Assessing Officer was justified in invoking Section 154 to make a fresh disallowance of ₹35.37 lakh under Section 14A read with Rule 8D, when such disallowance requires an adjudicatory exercise and satisfaction under Section 14A(2) rather than correcting… Read More »

Tribunal Rules in Favor of Insurer on Statutory Deductions and Transfer Pricing Adjustments

By | September 28, 2026
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Tribunal Rules in Favor of Insurer on Statutory Deductions and Transfer Pricing Adjustments Issues Depreciation & Profit on Sale of Fixed Assets: Whether statutory depreciation under Section 32 applies in place of book depreciation under Section 44 read with Rule 5, and if profit on sale of fixed assets must be reduced accordingly. Prior Period… Read More »