Monthly Archives: October 2026

Road-Cutting Restoration Charges Paid To PWD For Laying Gas Pipelines Constitute Taxable Supplies Under Reverse Charge Mechanism

By | October 16, 2026
0 Comment

Road-Cutting Restoration Charges Paid To PWD For Laying Gas Pipelines Constitute Taxable Supplies Under Reverse Charge Mechanism Issue Whether road restoration charges paid by a gas distribution company to the Public Works Department (PWD) for obtaining road-cutting permission to lay pipelines constitute a taxable supply of service under reverse charge, and whether such payments are… Read More »

Self-invoice value for imported IT support services from a related foreign affiliate is deemed open market value under Rule 28 when full ITC is available.

By | October 16, 2026
0 Comment

Self-invoice value for imported IT support services from a related foreign affiliate is deemed open market value under Rule 28 when full ITC is available. Issue Whether the value declared in the self-invoice raised by a GST-registered recipient for import of IT support services from a related foreign entity under reverse charge can be deemed… Read More »

Self-invoice value for imported IT support services from a related foreign affiliate is deemed open market value under Rule 28 when full ITC is available.

By | October 16, 2026
0 Comment

Self-invoice value for imported IT support services from a related foreign affiliate is deemed open market value under Rule 28 when full ITC is available. Issue Whether the value declared in the self-invoice raised by a GST-registered recipient for import of IT support services from a related foreign entity under reverse charge can be deemed… Read More »

INCOME TAX CASE LAWS 15.10.2026

By | October 16, 2026
0 Comment

INCOME TAX CASE LAWS 15.10.2026   Notifications & Case Laws Summary Relevant Act Section Case Law Title / Source Citation Brief Summary Income-tax Act, 2025 Section 159(1) CBDT Notification F. No. 135/2026 Click here CBDT notified the Protocol amending the India-Mauritius DTAA (signed March 07, 2024), introducing a new Article 27B (Principal Purpose Test) to… Read More »

Section 263 Revision Invalid On Issues Beyond Incriminating Material Uncovered During Search Proceedings

By | October 16, 2026
0 Comment

Section 263 Revision Invalid On Issues Beyond Incriminating Material Uncovered During Search Proceedings Issue Whether the Principal Commissioner can validly invoke revisionary jurisdiction under Section 263 to set aside a reassessment order for lack of inquiry into TDS on transportation charges under Section 40(a)(ia), when the reopening under Section 147/148 was triggered by search materials… Read More »

Interest On Enhanced Compensation Under Section 28 Is Capital Receipt Exempt Under Section 10(37), Rendering Section 263 Revision Invalid

By | October 16, 2026
0 Comment

Interest On Enhanced Compensation Under Section 28 Is Capital Receipt Exempt Under Section 10(37), Rendering Section 263 Revision Invalid Issue Whether interest received under Section 28 of the Land Acquisition Act, 1894 on enhanced compensation for compulsory acquisition of agricultural land is exempt under Section 10(37) or taxable under Section 56(2)(viii), and whether the PCIT… Read More »

Interim Board Settlement Applications Valid If Live Assessment Notice Pending On Filing Date

By | October 16, 2026
0 Comment

Interim Board Settlement Applications Valid If Live Assessment Notice Pending On Filing Date Issue Whether the Interim Board for Settlement can reject a settlement application filed on or before September 30, 2021, on the ground that no assessment proceeding was pending as on January 31, 2021, even though the assessee held a live and unadjudicated… Read More »

Supreme Court Dismisses Revenue’s SLP As En Masse Section 153D Search Approvals Lacked Application Of Mind

By | October 16, 2026
0 Comment

Supreme Court Dismisses Revenue’s SLP As En Masse Section 153D Search Approvals Lacked Application Of Mind Issue Whether the Supreme Court should interfere with the High Court’s order upholding the quashing of search assessment orders under Section 153A on the ground that the prior statutory approval granted under Section 153D by the Additional Commissioner suffered… Read More »

Section 147A Struck Down As Unconstitutional; Reassessments Initiated By Jurisdictional Assessing Officers Quashed For Lack Of Jurisdiction

By | October 16, 2026
0 Comment

Section 147A Struck Down As Unconstitutional; Reassessments Initiated By Jurisdictional Assessing Officers Quashed For Lack Of Jurisdiction Issue Whether Section 147A of the Income-tax Act, 1961 (inserted retrospectively by Finance Act, 2026) is unconstitutional for overriding judicial precedents and violating the doctrine of separation of powers, and whether reassessment proceedings initiated by Jurisdictional Assessing Officers… Read More »

Rectified Defective Return Relates Back To Original Filing Date, Making Delayed Section 143(2) Notice Time-Barred

By | October 16, 2026
0 Comment

Rectified Defective Return Relates Back To Original Filing Date, Making Delayed Section 143(2) Notice Time-Barred Issue Whether rectifying a defective return under Section 139(9) extends the limitation period for issuing a notice under Section 143(2), or if limitation must be calculated from the original filing date, rendering a delayed notice time-barred and the assessment invalid.… Read More »