Supreme Court Dismisses Special Leave Petition Upholding Stepping Up of Pay for Seniors Earning Less Than Juniors Issue Whether the Department can deny the “stepping up of pay” to senior employees to bring them at par with their juniors—who draw a higher salary due to advance increments received upon passing a departmental examination later in… Read More »

Mechanical Technical Approval Granted Under Section 153D Without Application of Mind Vitiates Search Assessments Issue Issue I (Mechanical Approval under Section 153D): Whether an assessment framed under section 153C is legally sustainable if the Joint Commissioner of Income Tax (JCIT) grants statutory approval under section 153D using the nomenclature “Technical Approval,” implying a routine formality… Read More »

Tribunal Can Remand Matter to Direct Valuation Officer Reference for Disputed Asset Allocation Under Section 50C Issue Whether the Income Tax Appellate Tribunal, while exercising its appellate powers under section 254, has the legal authority to remand a matter and direct the Assessing Officer to refer a property valuation to the Departmental Valuation Officer (DVO),… Read More »

Final Trust Registration Relates Back to Provisional Period and Infrastructure Capital Expenditure Qualifies as Valid Application of Income Issue Issue I (Doctrine of Relating Back): Whether a charitable trust holding provisional registration can be denied tax exemption under section 11 on the ground that its final registration, though granted later following a remand by the… Read More »

Telecom Company Secures Complete Victory Across Major Corporate, International Tax, and Accounting Reconciliation Issues Issue Whether multiple ad hoc additions and disallowances made by the Assessing Officer concerning business discounts, international interconnect charges, spectrum amortisation, outstanding government loans, timing-based ledger mismatches, and rule-based calculations without actual exempt income can be legally sustained under the Income-tax… Read More »

Chartered Accountant Acting as Conduit for Client Tax Payments Cannot Be Taxed for Unexplained Bank Deposits Issue Whether substantial cash/credit deposits found in the bank account of a Chartered Accountant can be added to his income as “unexplained money” under section 69A of the Income-tax Act, when the corresponding debit entries and tax challans establish… Read More »

Bank Liable for TDS Non-Deduction and Interest on Leave Fare Concession Involving Foreign Travel Issue Whether a bank can be treated as an “assessee in default” under section 201 of the Income-tax Act and held liable for consequential interest under section 201(1A) for failing to deduct tax at source (TDS) on Leave Fare Concession (LFC)… Read More »