Category Archives: Income Tax

Subsequent Capital Gains Utilized for Improving an Existing Exempt Residential Property Qualify under Section 54F

By | June 27, 2026
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Subsequent Capital Gains Utilized for Improving an Existing Exempt Residential Property Qualify under Section 54F Issue Whether an assessee is entitled to claim an exemption under Section 54F of the Income-tax Act, 1961, for long-term capital gains utilized toward the further construction and structural improvement of an existing residential property, when the initial purchase of… Read More »

Mandatory Contractual Site Restoration Provisions Are Fully Deductible and Cannot Be Added Back to Book Profits

By | June 27, 2026
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Mandatory Contractual Site Restoration Provisions Are Fully Deductible and Cannot Be Added Back to Book Profits Issue Whether a provision for site restoration expenses made pursuant to a mandatory contract with the Government of India is allowable as a business deduction under Section 37(1) of the Income-tax Act, 1961. Whether such a provision constitutes an… Read More »

Contractual Site Restoration Provisions Are Fully Deductible and Reassessment Lacking Recorded Reasons Is Invalid

By | June 27, 2026
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Contractual Site Restoration Provisions Are Fully Deductible and Reassessment Lacking Recorded Reasons Is Invalid Issue Whether a provision made for site restoration expenses by a non-resident petroleum company under a Production Sharing Contract is an allowed business deduction under Section 37(1) and an ascertained liability for Section 115JA book profit computation. Whether a reassessment undertaken… Read More »

Interest Paid on Funds Borrowed for Commercial Expediency to Acquire Controlling Interest is Fully Deductible

By | June 27, 2026
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Interest Paid on Funds Borrowed for Commercial Expediency to Acquire Controlling Interest is Fully Deductible Issue Whether the interest paid on capital borrowed by an assessee to acquire shares in a company through a group concern is deductible under Section 36(1)(iii) of the Income-tax Act, 1961, when evaluated under the touchstone of commercial expediency. Facts… Read More »

Benefit of Subsequent Section 12AA Registration Applies Retrospectively to Pending Prior Year Assessments

By | June 27, 2026
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Benefit of Subsequent Section 12AA Registration Applies Retrospectively to Pending Prior Year Assessments Issue Whether the benefit of a Section 12AA registration granted in a subsequent year can be applied retrospectively to open/pending assessment proceedings for an earlier assessment year under the proviso to Section 12A(2). Whether cash donations received for religious activities and deposited… Read More »

CIT(E) Cannot Reject Section 12AB and 80G Renewals for Objects It Already Formally Approved

By | June 27, 2026
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CIT(E) Cannot Reject Section 12AB and 80G Renewals for Objects It Already Formally Approved Issue Whether the CIT(E) was justified in rejecting the renewal of registration under Section 12AB and the consequential approval under Section 80G on the procedural grounds of delayed filing after modification of objects, when the CIT(E) itself had already granted approval… Read More »

Deemed Application of Income Spent on Immovable Property Does Not Require Schedule-I Disclosure under Form I-TR7

By | June 27, 2026
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Deemed Application of Income Spent on Immovable Property Does Not Require Schedule-I Disclosure under Form I-TR7 Issue Whether the addition of approximately ₹4.00 crores was sustainable under Section 11 of the Income-tax Act, 1961, when the assessing authorities disallowed a valid utilization of “deemed application” of income from the preceding year solely due to its… Read More »

INCOME TAX CASE LAWS 24.06.2026

By | June 26, 2026
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INCOME TAX CASE LAWS 24.06.2026 Relevant Act Section Case Law Title Citation Brief Summary Income Tax Act, 1961 Sec 2(14) Chakravati Chiman v. Income-tax Officer 2026 Click Here Where Sub-Registrar documents and the sale deed confirmed the rural agricultural nature of land, and no contrary evidence was presented, the addition of LTCG was deleted. Income… Read More »

Income tax demands not part of an NCLT-approved resolution plan stand completely extinguished.

By | June 26, 2026
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Income tax demands not part of an NCLT-approved resolution plan stand completely extinguished. Issue Whether the Revenue can legally enforce a Section 156 demand notice for pre-moratorium tax liabilities after a corporate resolution plan has been formally approved by the National Company Law Tribunal (NCLT) under the Insolvency and Bankruptcy Code, 2016 (IBC). Facts The… Read More »

An Assessing Officer cannot issue multiple draft assessment orders for the same assessment year.

By | June 26, 2026
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An Assessing Officer cannot issue multiple draft assessment orders for the same assessment year. Issue Whether the Assessing Officer is legally permitted to issue two separate draft assessment orders for the same assessment proceedings to initiate distinct Dispute Resolution Panel (DRP) processes, and whether corporate tax additions made in the final assessment order without corresponding… Read More »