Category Archives: Income Tax

DGAP Anti-Profiteering Computation Based on Purchase Value, Actual ITC, GST Addition, and Interest Upheld

By | October 6, 2026
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DGAP Anti-Profiteering Computation Based on Purchase Value, Actual ITC, GST Addition, and Interest Upheld Issue Whether the Director General of Anti-Profiteering (DGAP) complied with the project-level saving and per sq. ft. distribution methodology mandated in Reckitt Benckiser by utilizing purchase value instead of turnover. Whether an assessee can claim a notional adjustment for unavailed pre-GST… Read More »

Reassessment Orders Issued with Sanction from Incompetent Authority After Three Years Are Void and Unsalvageable Under Section 263

By | October 6, 2026
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Reassessment Orders Issued with Sanction from Incompetent Authority After Three Years Are Void and Unsalvageable Under Section 263 Issue Whether reassessment notices and orders issued after more than three years from the end of the relevant assessment year are legally valid when approval under Section 151 was obtained from the Principal Commissioner under clause (i)… Read More »

Reassessment Notice Issued Beyond Four Years Without Proof of Valid Sanction Under Section 151 Is Invalid

By | October 6, 2026
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Reassessment Notice Issued Beyond Four Years Without Proof of Valid Sanction Under Section 151 Is Invalid Reassessment Notice Issued Beyond Four Years Without Proof of Valid Sanction Under Section 151 Is Invalid Issue Whether a reassessment notice issued under Section 148 beyond four years from the end of the relevant assessment year is legally valid… Read More »

Reassessment Notice Based on Mere Reason to Suspect Without Definite Escapement Belief Is Invalid and Quashed

By | October 6, 2026
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Reassessment Notice Based on Mere Reason to Suspect Without Definite Escapement Belief Is Invalid and Quashed Issue Whether a notice issued under Section 148 for reassessment under Section 147 is legally sustainable when the reasons recorded by the Assessing Officer merely indicate a need for verification or lack of supporting details, amounting to a “reason… Read More »

Transfer Pricing Adjustment on Same Terms CCD Interest Unustified; Section 94B Recomputation Remanded

By | October 6, 2026
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Transfer Pricing Adjustment on Same Terms CCD Interest Unustified; Section 94B Recomputation Remanded Transfer Pricing Adjustment on Same Terms CCD Interest Unustified; Section 94B Recomputation Remanded Issue Whether TP adjustment treating ALP of interest on CCDs as Nil is sustainable when issued to AE and non-AE on identical terms. Whether the AO should re-verify and… Read More »

Cash deposits during demonetisation cannot be treated as unexplained money under section 69A when supported by regular books and business receipts.

By | October 6, 2026
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Cash deposits during demonetisation cannot be treated as unexplained money under section 69A when supported by regular books and business receipts. Cash deposits during demonetisation cannot be treated as unexplained money under section 69A when supported by regular books and business receipts. Issue Whether cash deposits made during the demonetisation period can be treated as… Read More »

Investments and Advances Carried Over From Preceding Year Fully Disclosed in Books Cannot Be Addition Under Section 69

By | October 6, 2026
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Investments and Advances Carried Over From Preceding Year Fully Disclosed in Books Cannot Be Addition Under Section 69 Issue Whether an addition made under Section 69 read with Section 115BBE of the Income-tax Act, 1961 as unexplained investments is sustainable when the investments and short-term loans/advances were already disclosed in audited books and carried forward… Read More »

Supreme Court Dismisses Review Petition Under Section 68 As Publicly Available Documents Do Not Constitute New Evidence

By | October 6, 2026
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Supreme Court Dismisses Review Petition Under Section 68 As Publicly Available Documents Do Not Constitute New Evidence Supreme Court Dismisses Review Petition Under Section 68 As Publicly Available Documents Do Not Constitute New Evidence Issue Whether a review petition can be entertained under Order XLVII Rule 1 of the Code of Civil Procedure, 1908 to… Read More »

Reassessment Notice Issued to a Deceased Person and Solely Based on a Co-Owner’s DVO Report Is Void

By | October 6, 2026
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Reassessment Notice Issued to a Deceased Person and Solely Based on a Co-Owner’s DVO Report Is Void Issue Whether reassessment notices issued under Section 148 in the name of a deceased person, relying solely on a DVO report obtained in a co-owner’s case, are legally valid under Sections 159, 149, and 55A of the Income-tax… Read More »

Registration of Sale Deed Does Not Shift Taxability to a Subsequent Year When Consideration and Possession Were Completed Earlier

By | October 6, 2026
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Registration of Sale Deed Does Not Shift Taxability to a Subsequent Year When Consideration and Possession Were Completed Earlier Registration of Sale Deed Does Not Shift Taxability to a Subsequent Year When Consideration and Possession Were Completed Earlier Issue Whether section 43CA can be invoked in AY 2016-17 upon subsequent registration of a sale deed… Read More »