Category Archives: Income Tax

Delayed Receivables Subsumed Under TNMM and Working Capital Adjustment Cannot Face Separate Notional Interest Imposition

By | July 2, 2026
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Delayed Receivables Subsumed Under TNMM and Working Capital Adjustment Cannot Face Separate Notional Interest Imposition Issue Whether a separate Transfer Pricing (TP) adjustment by imputing notional interest on delayed trade receivables from Associated Enterprises (AEs) is legally sustainable when the transaction has already been benchmarked under the Transactional Net Margin Method (TNMM) and a working… Read More »

Entire Bogus Purchase Value Cannot Be Taxed When Corresponding Sales Are Undisputed

By | July 2, 2026
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Entire Bogus Purchase Value Cannot Be Taxed When Corresponding Sales Are Undisputed Issue Whether the Assessing Officer is justified in adding the entire value of alleged bogus purchases to the assessee’s taxable income under Section 69C when the corresponding sales are accepted, no stock discrepancies exist, and only the profit element embedded in those purchases… Read More »

Reassessment Notice Based on Loose Seized Notings Lacking Direct Link to Assessee Is Quashed

By | July 2, 2026
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Reassessment Notice Based on Loose Seized Notings Lacking Direct Link to Assessee Is Quashed Issue Whether the Assessing Officer (AO) can validly issue a reassessment notice under Section 148 on the presumption of “on-money” payment, based solely on an entry in a third-party seized register that was recorded 23 months prior to the actual land… Read More »

Statutorily mandated deposits qualify for section 80P deduction, but surplus fund interest is taxed under section 56.

By | July 2, 2026
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Statutorily mandated deposits qualify for section 80P deduction, but surplus fund interest is taxed under section 56. Issue Whether interest income earned on deposits maintained by a co-operative society under statutory compulsion (such as SLR/reserve fund requirements) qualifies as business income eligible for deduction under Section 80P(2)(a)(i). Whether interest or dividend income earned from investing… Read More »

Assessee Entitled To Depreciation On Amalgamation Goodwill And Debt-Free Companies Are Exempt From Notional Interest Adjustments

By | July 2, 2026
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Assessee Entitled To Depreciation On Amalgamation Goodwill And Debt-Free Companies Are Exempt From Notional Interest Adjustments Issue Whether an assessee is entitled to claim depreciation at 25% under section 32(1)(ii) on goodwill arising out of an amalgamation scheme approved by the High Court, in the absence of any specific statutory embargo. Whether a Transfer Pricing… Read More »

INCOME TAX CASE LAWS 27.06.2026

By | June 30, 2026
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INCOME TAX CASE LAWS 27.06.2026   Relevant Act Section Case Law Title Citation Brief Summary Income-tax Act, 1961 Sec 2(47) Income-tax Officer v. Ramesh Shankarlal Bhandari Click Here Relinquishing all development and possessory rights over a land parcel for a lump-sum consideration amounts to a ‘transfer’. The assessee is entitled to the full indexed cost… Read More »

Concealment penalty under Section 271(1)(c) is unsustainable when quantum addition is based on estimation.

By | June 30, 2026
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Concealment penalty under Section 271(1)(c) is unsustainable when quantum addition is based on estimation. Issue Whether the Tribunal was correct in law by setting aside a concealment penalty levied under Section 271(1)(c) on the ground that the underlying quantum addition for bogus purchases had been restricted and sustained purely on an estimated percentage (12.5%). Facts… Read More »

Assessment is time-barred and invalid if the Assessing Officer fails to pass an order within the prescribed statutory period after a Tribunal remand.

By | June 30, 2026
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Assessment is time-barred and invalid if the Assessing Officer fails to pass an order within the prescribed statutory period after a Tribunal remand. Assessment is time-barred and invalid if the Assessing Officer fails to pass an order within the prescribed statutory period after a Tribunal remand. Issue Whether the failure of the Assessing Officer to… Read More »

Condonation of delay for filing Form 10-IC is rejected due to prolonged corporate non-compliance.

By | June 30, 2026
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Condonation of delay for filing Form 10-IC is rejected due to prolonged corporate non-compliance. Issue Whether the Commissioner was legally justified in rejecting the assessee-company’s application under Section 119(2)(b) for condonation of delay in filing Form 10-IC to claim the concessional tax rate under Section 115BAA, when the application was filed beyond the three-year limit… Read More »

Assessment order violating natural justice is maintainable under writ jurisdiction and liable to be quashed.

By | June 30, 2026
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Assessment order violating natural justice is maintainable under writ jurisdiction and liable to be quashed. Issue Whether a writ petition under Article 226 of the Constitution of India is maintainable against a high-demand assessment order passed in violation of the principles of natural justice and mandatory statutory procedures, despite the availability of an alternative statutory… Read More »