Reassessment Notice Beyond Three Years Is Invalid If Escaped Income Is Below Fifty Lakhs Reassessment Notice Beyond Three Years Is Invalid If Escaped Income Is Below Fifty Lakhs Issue Whether a reassessment notice issued under Section 148 beyond the three-year limitation period is valid when the initial allegation of unexplained cash deposits is dropped and… Read More »
Reassessment Cannot Be Sustained Where Reduction in Work-in-Progress Decreases Taxable Profit Without Escapement Reassessment Cannot Be Sustained Where Reduction in Work-in-Progress Decreases Taxable Profit Without Escapement Issue Whether reassessment proceedings under Section 147/148 are legally sustainable when an alleged higher valuation of closing Work-in-Progress (WIP) actually increases taxable income rather than causing income escapement, and… Read More »
Ex-Parte Assessment Remanded to Provide Assessee Fresh Opportunity of Hearing Under Principles of Natural Justice Ex-Parte Assessment Remanded to Provide Assessee Fresh Opportunity of Hearing Under Principles of Natural Justice Issue Whether an ex-parte assessment order under Section 144 and penalty under Section 271(1)(c) should be set aside and remanded for fresh adjudication when the… Read More »
Derivative Contract Value Cannot Be Closing Stock Nor Can Prior Year Opening Balances Be Taxed Under Section 69A Issue Whether derivative “sauda” (contract) value can be treated as closing stock to inflate capital, and whether Section 69A can be invoked to tax opening capital balances representing previous year closing balances as unexplained money. Facts The… Read More »
Stamp Duty Value on Date of Agreement Applies Under Proviso to Section 50C for Unregistered Agreements Stamp Duty Value on Date of Agreement Applies Under Proviso to Section 50C for Unregistered Agreements Issues Applicability of Stamp Duty Value on Date of Agreement: Whether the proviso to Section 50C requires an agreement to sell to be… Read More »
Remand Required to Verify Dual Salary Ledgers and Cash Payment Claims Under Section 40A(3) Remand Required to Verify Dual Salary Ledgers and Cash Payment Claims Under Section 40A(3) Issue Whether the disallowance of salary expenditure under Section 40A(3) for cash payments exceeding the prescribed limit is sustainable without complete verification of the assessee’s voluminous expense… Read More »
Processing Return Under Section 143(1) Post Section 143(2) Notice Is Valid and ESOP Cross-Charge Expenses Are Allowable Business Deductions Processing Return Under Section 143(1) Post Section 143(2) Notice Is Valid and ESOP Cross-Charge Expenses Are Allowable Business Deductions Issue Validity of Section 143(1) Processing Post Section 143(2) Notice & Doctrine of Merger: Whether processing a… Read More »
No TDS Applies to Cost Reimbursements Where Tax Was Deducted at Source Initially No TDS Applies to Cost Reimbursements Where Tax Was Deducted at Source Initially Issues TDS on Reimbursement of Apportioned Expenses: Whether Section 40(a)(ia) applies to payments made by an assessee to an association towards reimbursement of its share of legal expenses where… Read More »
Extraordinary COVID-19 Overhead Costs Must Be Excluded as Non-Operating and TP Adjustments Must Be Restricted to AE Transactions Issues Exclusion of Extraordinary COVID-19 Fixed Overheads: Whether extraordinary fixed overhead costs (salaries, depreciation, etc.) incurred during COVID-19 lockdown without generating operating revenue should be treated as non-operating expenses and excluded from the Profit Level Indicator (PLI)… Read More »
Supreme Court Dismisses Revenue’s SLP as Withdrawn, Upholding That Section 14A Requires Actual Exempt Income Supreme Court Dismisses Revenue’s SLP as Withdrawn, Upholding That Section 14A Requires Actual Exempt Income Issue Whether Section 14A of the Income-tax Act, 1961 (corresponding to Section 14 of the Income-tax Act, 2025) can be invoked to disallow expenditure when… Read More »