Category Archives: Income Tax

Consistency in Transfer Pricing Methods and Business Deductions Upheld, While Additional Depreciation Requires Integral New Capital Acquisition

By | June 18, 2026
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Consistency in Transfer Pricing Methods and Business Deductions Upheld, While Additional Depreciation Requires Integral New Capital Acquisition Issue Whether the Internal Transactional Net Margin Method (TNMM) can be replaced by the Comparable Uncontrolled Price (CUP) method if the Tribunal and High Court have consistently accepted TNMM for identical transactions in previous years. Whether Transfer Pricing… Read More »

CIT(A) Cannot Change Addition Sections Without Specific Notice, and Unreasonable Ad Hoc Disallowances Must Be Reduced

By | June 18, 2026
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CIT(A) Cannot Change Addition Sections Without Specific Notice, and Unreasonable Ad Hoc Disallowances Must Be Reduced Issue Whether the Commissioner of Income-tax (Appeals) [CIT(A)] can change the legal section of a tax addition (from Section 69C to Section 68) without issuing a specific show-cause notice to the assessee. Whether an ad hoc disallowance of 20%… Read More »

Deductions Under Section 80HHC Are Not Reduced by Section 80IA, and Capital-Linked Sales-Tax Remissions Are Capital Receipts

By | June 18, 2026
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Deductions Under Section 80HHC Are Not Reduced by Section 80IA, and Capital-Linked Sales-Tax Remissions Are Capital Receipts Issue Whether business profits must be reduced by deductions allowed under Section 80IA while computing the deduction under Section 80HHC of the Income-tax Act, 1961. Whether a sales-tax remission granted under the West Bengal Incentive Scheme, 1993—explicitly linked… Read More »

Deductions Under Section 80HHC Are Not Reduced by Section 80IA, and Capital-Linked Sales-Tax Remissions Are Capital Receipts

By | June 18, 2026
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Deductions Under Section 80HHC Are Not Reduced by Section 80IA, and Capital-Linked Sales-Tax Remissions Are Capital Receipts Deductions Under Section 80HHC Are Not Reduced by Section 80IA, and Capital-Linked Sales-Tax Remissions Are Capital Receipts Issue Whether business profits must be reduced by deductions allowed under Section 80IA while computing the deduction under Section 80HHC of… Read More »

INCOME TAX CASE LAW DIGEST 15.09.2026

By | June 16, 2026
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INCOME TAX CASE LAW DIGEST 15.09.2026 INCOME TAX CASE LAW DIGEST 15.09.2026 Relevant Act Section(s) Case Law Title Citation Brief Summary Income Tax Act, 1961 CBDT Circular (Monetary Limits) / Section 260A Principal Commissioner of Income-tax vs. Taha Wires (P.) Ltd. Click Here The ITAT erred in dismissing the Revenue’s appeal based on low tax… Read More »

Assessment Under Section 153A Annulled For Want Of Valid Search Warrant And Panchnama In Assessee’s Name

By | June 16, 2026
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Assessment Under Section 153A Annulled For Want Of Valid Search Warrant And Panchnama In Assessee’s Name Issue Whether the Assessing Officer (AO) can legally assume jurisdiction under Section 153A and frame a search assessment against an individual whose premises were physically searched, but in whose name no valid search warrant was issued or panchnama drawn.… Read More »

Supreme Court COVID Extension Of Limitation Period Is Not Applicable To Departmental Assessment Proceedings

By | June 16, 2026
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Supreme Court COVID Extension Of Limitation Period Is Not Applicable To Departmental Assessment Proceedings Issue Whether the extension of the limitation period granted by the Supreme Court during the COVID-19 pandemic applies to administrative assessment proceedings conducted by the Income Tax Department, and whether the Tribunal’s refusal to apply this extension constitutes a “mistake apparent… Read More »

Assessing Officer Must Apply Uniform Profit Rates For Identical Businesses And Cannot Make Separate Expense Disallowances After Rejecting Books

By | June 16, 2026
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Assessing Officer Must Apply Uniform Profit Rates For Identical Businesses And Cannot Make Separate Expense Disallowances After Rejecting Books Issue Whether the Assessing Officer (AO) is justified in estimating a higher gross profit (GP) rate of $4\%$ for a liquor trader after rejecting their books, when a lower GP rate of $3.13\%$ was accepted for… Read More »

Medical Reimbursements Up To Exempted Limit Excluded From Fringe Benefit Tax Liability Of Employer

By | June 16, 2026
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Medical Reimbursements Up To Exempted Limit Excluded From Fringe Benefit Tax Liability Of Employer Issue Whether medical reimbursements up to the statutory limit of Rs. 15,000 per employee per annum, which are explicitly exempt from income tax in the hands of the employees, are liable to Fringe Benefit Tax (FBT) in the hands of the… Read More »