Category Archives: Income Tax

Internal TNMM governs chemical transfer pricing, while additional depreciation applies to storage tanks but is denied for routine spares.

By | June 19, 2026
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Internal TNMM governs chemical transfer pricing, while additional depreciation applies to storage tanks but is denied for routine spares. Issue Whether the tax authorities are legally justified in modifying transfer pricing methods (CUP vs. Internal TNMM), disallowing additional depreciation on plant spares and storage tanks, adjusting book profits under Section 115JB for prior-period expenses, capitalising… Read More »

High Court precedent binds TPO on comparables, while healthcare and IT services are functionally distinct from market research.

By | June 19, 2026
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High Court precedent binds TPO on comparables, while healthcare and IT services are functionally distinct from market research. Issue Whether the Transfer Pricing Officer (TPO) is justified in selectively applying filters and excluding historically accepted comparables despite binding High Court precedents, and whether software depreciation (60% vs 25%) and international travel expense disallowances warrant fresh… Read More »

Registration and written agreement are mandatory for firm’s depreciation on inherited partner properties, and high court rejects writ petition due to available appellate remedies.

By | June 19, 2026
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Registration and written agreement are mandatory for firm’s depreciation on inherited partner properties, and high court rejects writ petition due to available appellate remedies. Issue Whether a partnership firm can claim depreciation under Section 32 on immovable properties without a written, registered transfer deed by invoking Section 53A of the Transfer of Property Act, and… Read More »

Notional interest on interest-free loans to a non-viable subsidiary cannot be taxed under the real income principle.

By | June 19, 2026
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Notional interest on interest-free loans to a non-viable subsidiary cannot be taxed under the real income principle. Issue Whether the tax authorities are justified in adding and taxing notional interest under Section 5 on long-term interest-free advances given to a non-viable subsidiary company, when both entities agreed not to charge interest and judicial consistency supports… Read More »

ESOP discount is an ascertained business expenditure under Section 37(1), and no Section 14A disallowance can be made if no exempt income is earned.

By | June 19, 2026
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ESOP discount is an ascertained business expenditure under Section 37(1), and no Section 14A disallowance can be made if no exempt income is earned. Issue Whether the discount on the issuance of Employee Stock Option Plans (ESOPs) is an allowable business expenditure under Section 37(1) rather than a national or contingent liability, and whether a… Read More »

Tribunal rules primarily for assessee on onsite profits, exempt income disallowance, goodwill depreciation, and FTC, but mandates allocation of interest expenditure.

By | June 19, 2026
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Tribunal rules primarily for assessee on onsite profits, exempt income disallowance, goodwill depreciation, and FTC, but mandates allocation of interest expenditure. Tribunal rules primarily for assessee on onsite profits, exempt income disallowance, goodwill depreciation, and FTC, but mandates allocation of interest expenditure. Issue Whether the various additions and disallowances made by the Assessing Officer concerning… Read More »

INCOME TAX CASE LAWS 17.06.2026

By | June 18, 2026
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INCOME TAX CASE LAWS 17.06.2026 INCOME TAX CASE LAWS 17.06.2026 Here is the compiled data from your legal updates structured into a scannable, professional reference table. Case Law Summary Table Relevant Act Section Case Law Title Citation Brief Summary Income-tax Act, 2025 Section 536(2)(c) Guidelines for Compulsory Scrutiny Selection (Notification F.No.225/56/2026/ITA-II) Click Here CBDT issued… Read More »

Common Area Maintenance (CAM) Charges Property Expenses Are Governing Under Section 194C as Contractual Work, Not Under Section 194I as Rent

By | June 18, 2026
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Common Area Maintenance (CAM) Charges Property Expenses Are Governing Under Section 194C as Contractual Work, Not Under Section 194I as Rent Issue Whether Common Area Maintenance (CAM) charges paid by a tenant under a lease agreement are liable for Tax Deduction at Source (TDS) at the rate of 10% as “Rent” under Section 194I, or… Read More »

An Omnibus Satisfaction Note Failing to Identify Year-Wise Incriminating Material Invalidates Section 153C Proceedings

By | June 18, 2026
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An Omnibus Satisfaction Note Failing to Identify Year-Wise Incriminating Material Invalidates Section 153C Proceedings An Omnibus Satisfaction Note Failing to Identify Year-Wise Incriminating Material Invalidates Section 153C Proceedings Issue Whether search assessments under Section 153C are legally sustainable if the mandatory satisfaction note recorded by the Assessing Officer (AO) is omnibus in nature, fails to… Read More »

Reassessment Initiated Beyond Three Years Without Tangible Material Indicating Escapement of Fifty Lakhs or More Is Void

By | June 18, 2026
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Reassessment Initiated Beyond Three Years Without Tangible Material Indicating Escapement of Fifty Lakhs or More Is Void Issue Whether a reassessment notice issued under Section 148 for the Assessment Year 2015-16 is legally sustainable if it is issued beyond the standard three-year limitation period from the end of the relevant assessment year without any material… Read More »