Section 80-IB(10) Housing Deduction Cannot Be Restricted By Arbitrary and Erroneous Land Cost Substitution

By | June 27, 2026
0 Comment

Section 80-IB(10) Housing Deduction Cannot Be Restricted By Arbitrary and Erroneous Land Cost Substitution Section 80-IB(10) Housing Deduction Cannot Be Restricted By Arbitrary and Erroneous Land Cost Substitution Issue Whether the Commissioner (Appeals) was legally justified in rejecting a rectification application under Section 154 when the original order restricted a housing project’s deduction under Section… Read More »

Reopening Assessment Based Solely on Illegible Third-Party Loose Papers Lacking Nexus is Wholly Unsustainable

By | June 27, 2026
0 Comment

Reopening Assessment Based Solely on Illegible Third-Party Loose Papers Lacking Nexus is Wholly Unsustainable Issue Whether the revenue is legally justified in reopening an assessment under Section 147 and issuing a notice under Section 148 based entirely on an illegible loose paper seized from an unrelated third party, where the satisfaction note fails to establish… Read More »

Unsecured Loan Additions Deleted upon Proving Source and Transfer Pricing Issues Remanded for Fresh Verification

By | June 27, 2026
0 Comment

Unsecured Loan Additions Deleted upon Proving Source and Transfer Pricing Issues Remanded for Fresh Verification Unsecured Loan Additions Deleted upon Proving Source and Transfer Pricing Issues Remanded for Fresh Verification Issue Whether an addition under Section 68 can be sustained when the assessee provides comprehensive proof of the lender’s identity, creditworthiness, and source of funds.… Read More »

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

By | June 27, 2026
0 Comment

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
0 Comment

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
0 Comment

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
0 Comment

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
0 Comment

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
0 Comment

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
0 Comment

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 »