Daily Archives: October 27, 2026

Separate Events Cannot Be Aggregated Under Section 149(1A) Making Reassessment Beyond Threshold Invalid

By | October 27, 2026
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Separate Events Cannot Be Aggregated Under Section 149(1A) Making Reassessment Beyond Threshold Invalid Issue Whether cash payments made on different dates against distinct orders constitute separate events that cannot be aggregated under Section 149(1A) to meet the ₹50 lakh threshold for reassessment beyond three years. Whether reassessment proceedings under Section 148 initiated for Assessment Year… Read More »

Tenancy Right Surrender Falls Within Section 50C Ambit Requiring DVO Valuation Upon Dispute

By | October 27, 2026
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Tenancy Right Surrender Falls Within Section 50C Ambit Requiring DVO Valuation Upon Dispute Issue Whether the transfer or surrender of tenancy rights in an immovable property falls within the ambit of Section 50C of the Income-tax Act, 1961 as a capital asset. Whether the Assessing Officer (AO) is required to refer the valuation to a… Read More »

Claimed ESOP Expenditure Allowable Under Section 37(1) Rendering Section 263 Revision Order Invalid

By | October 27, 2026
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Claimed ESOP Expenditure Allowable Under Section 37(1) Rendering Section 263 Revision Order Invalid Issue Whether Section 17(2)(vi), which governs employee perquisite taxation, dictates the character or allowability of employee stock option (ESOP) compensation expenditure claimed by an employer under Section 37(1). Whether the Principal Commissioner of Income Tax (PCIT) can assume revisionary jurisdiction under Section… Read More »

Processed Statutory Explanation Does Not Apply Retrospectively To Disallow Expenditure Without Exempt Income Earned

By | October 27, 2026
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Processed Statutory Explanation Does Not Apply Retrospectively To Disallow Expenditure Without Exempt Income Earned Issue Whether the Explanation inserted in Section 14A of the Income-tax Act, 1961 by the Finance Act, 2022 applies retrospectively to Assessment Year 2014-15. Whether any disallowance under Section 14A read with Rule 8D can be made or sustained when no… Read More »

Societies Registration Act Prohibition Against Asset Distribution Negates Mutuality Preserving Charitable Trust Registration Scope

By | October 27, 2026
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Societies Registration Act Prohibition Against Asset Distribution Negates Mutuality Preserving Charitable Trust Registration Scope Issue Whether the Commissioner (Exemptions) was justified in refusing registration under Section 12AB by treating the assessee-society as a mutual benefit association, despite statutory provisions barring asset distribution among members upon dissolution. Whether the scope of enquiry at the stage of… Read More »