Category Archives: Income Tax

Mandatory CSR Expenditures to Registered Trusts Qualify for Section 80G Deductions and Working Capital Adjustments Preclude Separate Interest Imputation on Delayed Receivables

By | June 15, 2026

Mandatory CSR Expenditures to Registered Trusts Qualify for Section 80G Deductions and Working Capital Adjustments Preclude Separate Interest Imputation on Delayed Receivables Issue Whether an assessee can claim a tax deduction under Section 80G for corporate donations made to a registered, approved trust, even if that expenditure forms part of its mandatory Corporate Social Responsibility… Read More »

Forex Fluctions on Export Proceeds are Operating in Nature and CSR Donations Qualify for Section 80G Deductions

By | June 15, 2026

Forex Fluctions on Export Proceeds are Operating in Nature and CSR Donations Qualify for Section 80G Deductions Issue Whether foreign exchange gains/losses arising from the realization of normal export proceeds from Associated Enterprises (AEs) should be treated as operating in nature when computing the Profit Level Indicator (PLI) under the Transactional Net Margin Method (TNMM).… Read More »

Tax Authorities Cannot Arbitrarily Reverse Multi-Year Deductions or Disallow Reimbursed Employee ESOP Costs, But Share Issue Expenses Remain Capital in Nature

By | June 15, 2026

Tax Authorities Cannot Arbitrarily Reverse Multi-Year Deductions or Disallow Reimbursed Employee ESOP Costs, But Share Issue Expenses Remain Capital in Nature Issue Whether the Assessing Officer is justified in disallowing a multi-year amortization deduction under Section 35D in its final (5th) year when the same deduction was accepted and allowed without disturbance by the Revenue… Read More »

Serving Notice Solely Through the ITBA Portal is Invalid and Cannot Justify Denying Trust Registration or Approvals

By | June 15, 2026

Serving Notice Solely Through the ITBA Portal is Invalid and Cannot Justify Denying Trust Registration or Approvals Issue Whether serving statutory notices exclusively through the Income Tax Business Application (ITBA) portal constitutes a valid method of service under Section 282(1) read with Rule 127(1), and whether an application for fresh registration under Section 12AB can… Read More »

AIF Investment and Processing Fees Income Cannot Be Arbitrarily Reclassified as Taxable Business Income

By | June 15, 2026

AIF Investment and Processing Fees Income Cannot Be Arbitrarily Reclassified as Taxable Business Income Issue Whether the Assessing Officer was justified in re-characterizing the interest income, short-term capital gains, and processing fees of a SEBI-registered Category II Alternative Investment Fund (AIF) as business income, thereby denying tax exemption under Section 10(23FBA) read with Section 115UB… Read More »

INCOME TAX CASE LAW DIGEST 12.6.2026

By | June 13, 2026

INCOME TAX CASE LAW DIGEST 12.6.2026 INCOME TAX CASE LAW DIGEST 12.6.2026 Relevant Act Section(s) / Rule(s) Case Law Title Citation Brief Summary Income Tax Act, 1961 Section 10(23FBA) Deputy Commissioner of Income-tax vs. Sundaram Alternative Opp Series High Yield Secured Debt fund Click Here Exemption under Section 10(23FBA) is allowable for NCD processing fees… Read More »

Donations Sourced From Corporate Social Responsibility Funds Qualification Under Section 80G Are Fully Valid And Omitted Tax Credits Under Section 90 Must Be Factually Restored

By | June 13, 2026

Donations Sourced From Corporate Social Responsibility Funds Qualification Under Section 80G Are Fully Valid And Omitted Tax Credits Under Section 90 Must Be Factually Restored Donations Sourced From Corporate Social Responsibility Funds Qualification Under Section 80G Are Fully Valid And Omitted Tax Credits Under Section 90 Must Be Factually Restored Issue Whether a company can… Read More »

An Intimation Under Section 143(1) Does Not Merge Into A Scrutiny Assessment Order Passed Under Section 143(3) And Adjustments Therein Must Be Appealed Separately

By | June 13, 2026

An Intimation Under Section 143(1) Does Not Merge Into A Scrutiny Assessment Order Passed Under Section 143(3) And Adjustments Therein Must Be Appealed Separately Issue Whether an intimation issued under Section 143(1) merges into a subsequent scrutiny assessment order passed under Section 143(3) when the Assessing Officer merely adopts the income from the intimation without… Read More »

Notices Issued Solely Through The ITBA Portal Do Not Constitute Valid Service Of Notice And Consequential Denial Of Section 80G Approval Is Unsustainable

By | June 13, 2026

Notices Issued Solely Through The ITBA Portal Do Not Constitute Valid Service Of Notice And Consequential Denial Of Section 80G Approval Is Unsustainable Issue Whether the service of statutory show-cause notices issued exclusively via the Income Tax Business Application (ITBA) portal satisfies the valid modes of service prescribed under Section 282(1) read with Rule 127(1),… Read More »

Corporate Social Responsibility Spend Is Eligible For Section 80G Deductions And Working Capital Adjustments Preclude Separate Interest Imputations On Outstanding Receivables

By | June 13, 2026

Corporate Social Responsibility Spend Is Eligible For Section 80G Deductions And Working Capital Adjustments Preclude Separate Interest Imputations On Outstanding Receivables Issue Whether Corporate Social Responsibility (CSR) expenditure, which is statutorily disallowed as a business expense under Section 37(1), can be claimed as a deduction under Section 80G if the donation is made to a… Read More »