Additions under Sections 69A and 56(2)(x) are unsustainable when consideration is adjusted against prior mortgage liabilities, guideline values are disputed without independent evidence, and cash deposit explanations are rejected without objective verification.

By | August 6, 2026
0 Comment

Additions under Sections 69A and 56(2)(x) are unsustainable when consideration is adjusted against prior mortgage liabilities, guideline values are disputed without independent evidence, and cash deposit explanations are rejected without objective verification. Additions under Sections 69A and 56(2)(x) are unsustainable when consideration is adjusted against prior mortgage liabilities, guideline values are disputed without independent evidence,… Read More »

Reassessment beyond four years without new tangible material is an impermissible change of opinion and liable to be quashed.

By | August 6, 2026
0 Comment

Reassessment beyond four years without new tangible material is an impermissible change of opinion and liable to be quashed. Reassessment beyond four years without new tangible material is an impermissible change of opinion and liable to be quashed. Issue Whether reopening of assessment under section 147 beyond four years from the end of the relevant… Read More »

Out-of-court patent settlement, business promotion, R&D expenses, and related interest are allowable revenue deductions.

By | August 6, 2026
0 Comment

Out-of-court patent settlement, business promotion, R&D expenses, and related interest are allowable revenue deductions. Issue Whether out-of-court patent litigation settlement payments and interest on borrowings to fund such settlements are allowable business expenditures under section 37(1) and section 36(1)(iii). Whether TP adjustments on captive power plant transfers, AE sales, and loans/share application money can be… Read More »

Foreign exchange fluctuation loss on capital-purpose ECB restatement is capital in nature and non-deductible.

By | August 6, 2026
0 Comment

Foreign exchange fluctuation loss on capital-purpose ECB restatement is capital in nature and non-deductible. Issue Whether foreign exchange fluctuation loss arising on the year-end restatement of an External Commercial Borrowing (ECB) utilized for capital purposes is deductible as revenue business expenditure under section 37(1). Facts The assessee-company availed an External Commercial Borrowing (ECB) from its… Read More »

CIT(E) cannot attach caveats to High Court-mandated registration and approval based on prospective Supreme Court appeals.

By | August 6, 2026
0 Comment

CIT(E) cannot attach caveats to High Court-mandated registration and approval based on prospective Supreme Court appeals. CIT(E) cannot attach caveats to High Court-mandated registration and approval based on prospective Supreme Court appeals. Issue Whether CIT (Exemption) is justified in attaching a caveat/condition to registration under section 12AB and approval under section 80G stating that benefits… Read More »

Capitalization of interest is unjustified with sufficient interest-free funds, and Section 14A disallowance cannot increase MAT book profits.

By | August 6, 2026
0 Comment

Capitalization of interest is unjustified with sufficient interest-free funds, and Section 14A disallowance cannot increase MAT book profits. Capitalization of interest is unjustified with sufficient interest-free funds, and Section 14A disallowance cannot increase MAT book profits. Issue Whether interest expenditure can be capitalized under section 36(1)(iii) when the assessee possesses interest-free funds exceeding its investments… Read More »

Interest under section 40 of Black Money Act is unsustainable where foreign source was disclosed and tax statutory exemptions apply.

By | August 6, 2026
0 Comment

Interest under section 40 of Black Money Act is unsustainable where foreign source was disclosed and tax statutory exemptions apply. Issue Whether interest under section 40(1) can be levied when a foreign source is disclosed in the return filed under section 139(1) and the dispute relates only to the quantum of income. Whether interest under… Read More »

Disallowance under section 40(a)(ia) and 40(a)(i) is unsustainable as TDS provisions were not applicable.

By | August 6, 2026
0 Comment

Disallowance under section 40(a)(ia) and 40(a)(i) is unsustainable as TDS provisions were not applicable. Issue Whether section 40(a)(ia) can be invoked for player winnings payouts that were never claimed as deductible expenditure in the Profit and Loss account, and whether the ₹10,000 threshold under section 194B applies per individual payment rather than aggregate wallet balance.… Read More »

Interest Paid To Foreign HO Deductible, Hedging Capital Gains Exempt, Refund Interest Taxed At DTAA Capped Rate

By | August 6, 2026
0 Comment

Interest Paid To Foreign HO Deductible, Hedging Capital Gains Exempt, Refund Interest Taxed At DTAA Capped Rate Issue Whether interest paid by an Indian Permanent Establishment (PE) to its foreign Head Office (HO) and overseas branches is allowable as a deductible expense. Whether Transfer Pricing adjustment for guarantee commission under internal CUP should be restricted… Read More »

Section 40(a)(i) Disallowance Upheld On MFN Withdrawal, Goodwill Depreciation, POS Charges, Software Depreciation, Section 80JJAA Allowed

By | August 6, 2026
0 Comment

Section 40(a)(i) Disallowance Upheld On MFN Withdrawal, Goodwill Depreciation, POS Charges, Software Depreciation, Section 80JJAA Allowed Section 40(a)(i) Disallowance Upheld On MFN Withdrawal, Goodwill Depreciation, POS Charges, Software Depreciation, Section 80JJAA Allowed Issue Whether the disallowance under Section 40(a)(i) for export commission, depreciation on goodwill and software, revenue deduction for land development and Principal Only… Read More »