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Transfer Pricing: Re-characterization of Software Developer as ‘Contract R&D Provider’ Rejected; BAPA and Past TPO Orders Confirm ‘Software Development’ Status

By | December 31, 2025

Transfer Pricing: Re-characterization of Software Developer as ‘Contract R&D Provider’ Rejected; BAPA and Past TPO Orders Confirm ‘Software Development’ Status ISSUE Whether the Transfer Pricing Officer (TPO) was justified in re-characterizing the assessee as a “Software Research/R&D Service Provider” (instead of a “Software Development Service Provider”) based on US tax documents, despite a signed Bilateral… Read More »

Addition u/s 56(2)(vii)(b) Deleted: Allotment Letter Treated as Valid ‘Agreement’ for Determining Stamp Duty Value Date

By | December 31, 2025

Addition u/s 56(2)(vii)(b) Deleted: Allotment Letter Treated as Valid ‘Agreement’ for Determining Stamp Duty Value Date   ISSUE Whether an Allotment Letter issued by a builder can be treated as an “Agreement” for the purpose of the proviso to Section 56(2)(vii)(b), allowing the assessee to adopt the Stamp Duty Value (SDV) on the date of… Read More »

Key amendments in PFRDA (Exits and Withdrawals under the NPS) Regulations, 2015

By | December 20, 2025

Key amendments in PFRDA (Exits and Withdrawals under the NPS) Regulations, 2015 Amendments primarily aimed at the non-government sector, also rationalize provisions for government sector Measures to provide subscribers greater flexibility, choice and autonomy in investment decisions and aid managing accumulated pension wealth Posted On: 19 DEC 2025 8:16PM by PIB Delhi In furtherance of… Read More »

Supreme Court to Decide: Can GST Circulars Override Statutory Ban on Parallel Proceedings?

By | December 17, 2025

Supreme Court to Decide: Can GST Circulars Override Statutory Ban on Parallel Proceedings? Supreme Court Stays High Court Order The Supreme Court has stayed the operation of the Bombay High Court’s judgment in the case of Sree UGCL Projects Ltd. v. Additional Director (DG GST Intelligence). The Court issued a notice to the Revenue Department… Read More »

CA Exonerated: No Prosecution for Form 15CB Certificates Issued on Unknowingly Forged Documents

By | December 17, 2025

CA Exonerated: No Prosecution for Form 15CB Certificates Issued on Unknowingly Forged Documents Supreme Court Upholds Discharge The Hon’ble Supreme Court, in the case of The Deputy Director V. Murali Krishna Chakrala, upheld the Madras High Court’s judgment discharging a Chartered Accountant from prosecution under the Prevention of Money Laundering Act (PMLA). The Court confirmed… Read More »

Migration of UDIN Portal to ICAI DigiCA Platform

By | December 17, 2025

Migration of UDIN Portal to ICAI DigiCA Platform UDIN Directorate The Institute of Chartered Accountants of India 10th Dec 2025 The members are hereby informed that the Institute of Chartered Accountants of India (ICAI) is contemplating migration of the existing UDIN Portal to the ICAI DigiCA Platform on 20th December 2025. The upgraded system will provide improved… Read More »

Notification u/s 10(46) of the Income Tax Act, 1961 in the case of New Okhla Industrial Development Authority

By | December 17, 2025

Notification u/s 10(46) of the Income Tax Act, 1961 in the case of New Okhla Industrial Development Authority MINISTRY OF FINANCE (Department of Revenue) (CENTRAL BOARD OF DIRECT TAXES) NOTIFICATION New Delhi, the 15th December, 2025 S.O. 5779(E).— In exercise of the powers conferred by clause (46) of section 10 of the Income-tax Act, 1961… Read More »

Notification u/s 120(2)(1) of the Income Tax Act, 1961

By | December 17, 2025

Notification u/s 120(2)(1) of the Income Tax Act, 1961 MINISTRY OF FINANCE (Department of Revenue) (CENTRAL BOARD OF DIRECT TAXES) NOTIFICATION New Delhi, the 15th December, 2025 INCOME-TAX S.O. 5799(E).—In exercise of the powers conferred by sub-sections (1) and (2) of section 120 of the Income-tax Act, 1961 (43 of 1961), and in continuation to… Read More »

Notification u/s 10(46A) of the Income Tax Act, 1961 Punjab Urban Planning And Development Authority

By | December 17, 2025

Notification u/s 10(46A) of the Income Tax Act, 1961 Punjab Urban Planning And Development Authority MINISTRY OF FINANCE (Department of Revenue) (CENTRAL BOARD OF DIRECT TAXES) NOTIFICATION New Delhi, the 15th December, 2025 S.O. 5778(E).— In exercise of the powers conferred by sub-clause (b) of clause (46A) of section 10 of the Income-tax Act, 1961… Read More »

Reopening for Foreign Share Capital Quashed; Investor Accepted in Later Years

By | December 15, 2025

Reopening for Foreign Share Capital Quashed; Investor Accepted in Later Years Issue Whether the Assessing Officer (AO) can reopen an assessment under Section 147 alleging that share capital received from a foreign entity (‘GS’, Singapore) is unexplained cash credit (Section 68), when the same investor’s identity and creditworthiness were accepted by the Department in subsequent… Read More »