Amount Received on Termination of Joint Venture Agreement Using Trademarks and Patents Is Not Taxable Under Unamended Section 55(2)

By | July 30, 2026
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Amount Received on Termination of Joint Venture Agreement Using Trademarks and Patents Is Not Taxable Under Unamended Section 55(2) Issue Whether the amount received by the assessee on termination of a joint venture agreement involving the use of know-how, labels, trademarks, and patents was taxable as capital gains under Section 55(2) as it stood during… Read More »

Disallowance Under Section 14A Cannot Be Added When Computing Book Profits Under Section 115JB

By | July 30, 2026
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Disallowance Under Section 14A Cannot Be Added When Computing Book Profits Under Section 115JB Disallowance Under Section 14A Cannot Be Added When Computing Book Profits Under Section 115JB Issue Whether expenses disallowed under Section 14A read with Rule 8D can be added back to compute book profits under Section 115JB under Explanation 1(f) of the… Read More »

Redemption Fine Paid for Goods Confiscated Due to Import Law Violations Is Not Allowable Expenditure

By | July 30, 2026
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Redemption Fine Paid for Goods Confiscated Due to Import Law Violations Is Not Allowable Expenditure Issue Whether a redemption fine paid for releasing goods confiscated due to a breach of import conditions is an allowable business expenditure under Section 37(1). Facts Context: The matter pertains to Assessment Year 1988-89 involving the allowability of a redemption… Read More »

Write-off of Expired Inventory and Bad Debts Supported by Evidence Is Allowable

By | July 30, 2026
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Write-off of Expired Inventory and Bad Debts Supported by Evidence Is Allowable Issue Whether the write-off of expired finished goods inventory under Section 37(1) is allowable as a business expenditure when supported by physical verification and destruction norms. Whether the write-off of bad debts under Section 36 is allowable when substantiated by debtor details, sale… Read More »

Write-off of Expired Inventory and Bad Debts Supported by Evidence Is Allowable

By | July 30, 2026
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Write-off of Expired Inventory and Bad Debts Supported by Evidence Is Allowable Issue Whether the write-off of expired finished goods inventory under Section 37(1) is allowable as a business expenditure when supported by physical verification and destruction norms. Whether the write-off of bad debts under Section 36 is allowable when substantiated by debtor details, sale… Read More »

Reassessment Based on Re-examining Scrutinized Section 10AA Claim Amounts to Impermissible Change of Opinion

By | July 30, 2026
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Reassessment Based on Re-examining Scrutinized Section 10AA Claim Amounts to Impermissible Change of Opinion Reassessment Based on Re-examining Scrutinized Section 10AA Claim Amounts to Impermissible Change of Opinion Issue Whether the Assessing Officer was justified in issuing a reassessment notice under Section 148 to revisit a Section 10AA deduction claim that was already examined, queried,… Read More »

Section 10A Addition Is Invalid Without Material Proving Assessee’s Dealings Yielded More Than Ordinary Profits

By | July 30, 2026
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Section 10A Addition Is Invalid Without Material Proving Assessee’s Dealings Yielded More Than Ordinary Profits Issue Whether the Assessing Officer was justified in making additions under Section 10A(7) read with Section 80IA(10) merely because the assessee’s net profit margin (27.86%) was higher than the average profit margin of comparables (9.35%), without establishing that the dealings… Read More »

Delay in Filing Appeal Condoned as CA’s Procedural Error Constitutes Sufficient Cause

By | July 30, 2026
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Delay in Filing Appeal Condoned as CA’s Procedural Error Constitutes Sufficient Cause Issue Whether an inordinate delay of 1,797 days in filing an appeal before the CIT(A)/NFAC should be condoned and the matter restored for adjudication on merits when the delay was caused by an inadvertent error on the part of the tax consultant. Facts… Read More »

Interest from Head Office, Hub Costs, Broken-Period Interest, Salary Reimbursements, MTM Losses, and Securities Diminution Are Allowable

By | July 30, 2026
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Interest from Head Office, Hub Costs, Broken-Period Interest, Salary Reimbursements, MTM Losses, and Securities Diminution Are Allowable Issue Whether interest credited to an Indian Permanent Establishment (PE) branch by its foreign Head Office/overseas branches is taxable in India under Section 9 read with Article 7 of the India-USA DTAA. Whether centralized operational hub expenses paid… Read More »

Disallowance of Intangible Asset Depreciation on Opening WDV, Unearned Advance Subscription Revenue, and Interest on Inherited Slump-Sale Borrowings Is Impermissible Without Rebuttal or Finding of Unreasonableness

By | July 30, 2026
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Disallowance of Intangible Asset Depreciation on Opening WDV, Unearned Advance Subscription Revenue, and Interest on Inherited Slump-Sale Borrowings Is Impermissible Without Rebuttal or Finding of Unreasonableness Disallowance of Intangible Asset Depreciation on Opening WDV, Unearned Advance Subscription Revenue, and Interest on Inherited Slump-Sale Borrowings Is Impermissible Without Rebuttal or Finding of Unreasonableness Issue Whether depreciation… Read More »