Daily Archives: October 10, 2026

Uncorroborated Search Statements Cannot Sustain Additions, Section 14A Disallowance Impermissible Without Exempt Income, and Multi-Issue Assessment Matters Standardized

By | October 10, 2026

Uncorroborated Search Statements Cannot Sustain Additions, Section 14A Disallowance Impermissible Without Exempt Income, and Multi-Issue Assessment Matters Standardized Issue Whether an uncorroborated search statement under Section 132(4) alone can sustain tax additions. Whether disallowance under Section 14A read with Rule 8D is permissible when no exempt income is earned. Whether the Assessing Officer correctly assumed… Read More »

Reassessment of DDT Tax Rate under DTAA Remanded and Market Research Expenses Allowed as Deductible

By | October 10, 2026

Reassessment of DDT Tax Rate under DTAA Remanded and Market Research Expenses Allowed as Deductible Issue Whether an additional ground claiming lower tax rate under India-Singapore DTAA on Dividend Distribution Tax (DDT) under Section 115-O can be admitted and remanded for AO’s consideration. Whether Market Research and Media Measurement expenses incurred for client advertising services… Read More »

Foreign Bank PE Faces Higher Tax, Intra-Entity Interest Adjustments, Computer Depreciation on ATMs, Full Lease Deduction

By | October 10, 2026

Foreign Bank PE Faces Higher Tax, Intra-Entity Interest Adjustments, Computer Depreciation on ATMs, Full Lease Deduction Issue Whether charging a higher tax rate on a foreign bank’s PE violates DTAA non-discrimination rules. Whether interest paid by an Indian PE to its overseas head office is subject to Section 195 TDS and Section 40(a)(i) disallowance. Whether… Read More »

Reopening Notice Issued by Non-Jurisdictional Assessing Officer After Section 127 Transfer Order Is Void and Quashed

By | October 10, 2026

Reopening Notice Issued by Non-Jurisdictional Assessing Officer After Section 127 Transfer Order Is Void and Quashed Issue Whether a reassessment notice issued under Section 148 of the Income-tax Act, 1961 by an Assessing Officer who lost territorial jurisdiction due to a prior transfer order under Section 127 is legally valid or liable to be quashed.… Read More »