Daily Archives: October 12, 2026

Assessment Order Cannot Be Revisioned Under Section 263 for Issues Beyond Limited Scrutiny Scope

By | October 12, 2026

Assessment Order Cannot Be Revisioned Under Section 263 for Issues Beyond Limited Scrutiny Scope Issue Whether a Principal Commissioner can invoke revisionary powers under Section 263 on an issue beyond the scope of limited scrutiny when the Assessing Officer did not examine it during assessment. Facts Limited Scrutiny Selection: For Assessment Year 2020-21, the assessee-company’s… Read More »

No Satisfaction Recorded for Section 14A and Arbitrary Pro-Rata Royalty Expenditure Allocation Remanded

By | October 12, 2026

No Satisfaction Recorded for Section 14A and Arbitrary Pro-Rata Royalty Expenditure Allocation Remanded Issue Whether an additional disallowance under Section 14A read with Rule 8D can be made without the Assessing Officer recording objective dissatisfaction regarding the correctness of the assessee’s suo motu disallowance. Whether Section 115BBF(2) permits a blanket disallowance of general business expenditure… Read More »

Form 10 Filed in Time Validates Income Accumulation Regardless of Late Board Resolution Date

By | October 12, 2026

Form 10 Filed in Time Validates Income Accumulation Regardless of Late Board Resolution Date Issue Whether an exemption under Section 11(2) for accumulation of income can be denied solely on the ground that the Board of Trustees passed the authorization resolution after the close of the financial year, even though Form 10 was filed within… Read More »

Land Distance to be Reckoned from Expanded Municipal Limits and Dishonoured Cheque Does Not Reduce Sale Consideration

By | October 12, 2026

Land Distance to be Reckoned from Expanded Municipal Limits and Dishonoured Cheque Does Not Reduce Sale Consideration Issue Whether the distance of agricultural land from municipal limits for determining its status as a capital asset under Section 2(14) should be measured from the expanded municipal boundaries existing on the date of transfer. Whether non-receipt of… Read More »