Category Archives: Income Tax

Non-resident bank wins on inter-branch transactions, interest, exemptions, and key business expense deductions.

By | July 6, 2026
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Non-resident bank wins on inter-branch transactions, interest, exemptions, and key business expense deductions. Issue Whether various additions and disallowances made by the Assessing Officer concerning inter-branch transactions, overseas third-party bank interest, expense allocations ($§14\text{A}$), write-backs, broken period interest, club fees, interest on processing refunds ($§234\text{B}$), year-end forex revaluations, and CRR/SLR shortfalls are legally sustainable under… Read More »

Consideration received for transferring property development rights is taxable exclusively under Capital Gains.

By | July 6, 2026
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Consideration received for transferring property development rights is taxable exclusively under Capital Gains. Issue Whether development rights in an immovable property constitute a “capital asset” under Section 2(14) of the Income-tax Act, making the contractual consideration received for their transfer taxable under the head “Capital Gains” rather than “Income from Other Sources.” Facts The Agreement:… Read More »

Consideration received for transferring development rights is taxable as capital gains, not other sources.

By | July 6, 2026
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Consideration received for transferring development rights is taxable as capital gains, not other sources. Issue Whether development rights in an immovable property constitute a “capital asset” under Section 2(14), making the contractual consideration received for their transfer taxable under the head “Capital Gains” rather than “Income from Other Sources.” Facts Agreement: The assessee, along with… Read More »

Condonation of Delay for Filing Electronic Form 10AB Under Section 80G(5)

By | July 6, 2026
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Condonation of Delay for Filing Electronic Form 10AB Under Section 80G(5) CONDONATION OF DELAY IN FILING FORM NO. 10AB ELECTRONICALLY FOR APPROVAL UNDER CLAUSE (ii) OF THE FIRST PROVISO TO SECTION 80G(5) OF THE INCOME-TAX ACT, 1961 CIRCULAR NO. 6/2026 [F. NO. 300176/3/2026-ITA-I], DATED 2-7-2026 Section 80G of the Income-tax Act, 1961 (“the Act”) provides for deduction in… Read More »

Income Tax Exemption Notification for Statutory Bodies and Authorities Under Section 10(46)

By | July 6, 2026
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Income Tax Exemption Notification for Statutory Bodies and Authorities Under Section 10(46)   SECTION 10(46) OF THE INCOME-TAX ACT, 1961, READ WITH SECTION 536 OF THE INCOME-TAX ACT, 2025 – EXEMPTIONS – STATUTORY BODY/AUTHORITY/BOARD/COMMISSION – NOTIFIED BODY OR AUTHORITY NOTIFICATION S.O. 3596(E) [NO. 73 /2026/F. NO. 300196/32/2021-ITA-I], DATED 2-7-2026 Whereas, section 10 (46) of the Income-tax Act, 1961 (43… Read More »

INCOME TAX CASE LAWS 03.07.2026

By | July 4, 2026
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INCOME TAX CASE LAWS 03.07.2026 Relevant Act Section Case Law Title Citation Brief Summary Income-tax Act, 1961 Sec 2(15) Reliance Foundation Hospital Trust v. CIT (Exemptions) 2026 Click Here Offering premium rooms/high tariffs does not wipe out a hospital’s charitable nature as long as the generated surplus is devoted back to charitable purposes. Income-tax Act,… Read More »

Section 153C assessments are quashed because satisfaction notes recorded post-April 1, 2021, render proceedings non-est and time-barred.

By | July 4, 2026
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Section 153C assessments are quashed because satisfaction notes recorded post-April 1, 2021, render proceedings non-est and time-barred. Issue Whether the assessment orders passed under Section 153C for AY 2015-16, 2016-17, and 2017-18 are legally sustainable when the mandatory satisfaction note was recorded on October 11, 2022 (Financial Year 2022-23), shifting the statutory block period and… Read More »

Section 153C assessments are invalid for excluded block periods and unabated years lacking incriminating material.

By | July 4, 2026
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Section 153C assessments are invalid for excluded block periods and unabated years lacking incriminating material. Issue Issue 1: Whether the block of six assessment years under Section 153C must be reckoned from the deemed date of search (the date the satisfaction note is recorded), thereby excluding years that fall outside this newly calculated window. Issue… Read More »

Assessment under section 153C is void if the satisfaction note is recorded after April 1, 2021.

By | July 4, 2026
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Assessment under section 153C is void if the satisfaction note is recorded after April 1, 2021. Issue Whether the assessment orders framed under Section 153C for the assessment years 2013-14 and 2014-15 are legally valid, given that the Assessing Officer’s satisfaction note was recorded after April 1, 2021, shifting the deemed date of search for… Read More »

Section 80-IB deduction does not reduce profits for computing Section 80HHC deduction; matter remanded.

By | July 4, 2026
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Section 80-IB deduction does not reduce profits for computing Section 80HHC deduction; matter remanded. Issue Whether the restriction under Section 80-IA(9) requires the deduction under Section 80-IB to be reduced from business profits before computing the Section 80HHC deduction, or if it merely restricts the final allowability of the total deductions. Facts For the assessment… Read More »