Reopening Order Set Aside and Remanded for Non-Conduct of Inquiry Under Section 148A(a) Despite Prior Approval

By | July 27, 2026
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Reopening Order Set Aside and Remanded for Non-Conduct of Inquiry Under Section 148A(a) Despite Prior Approval Reopening Order Set Aside and Remanded for Non-Conduct of Inquiry Under Section 148A(a) Despite Prior Approval Issue Whether an order passed under Section 148A(d) and subsequent notice issued under Section 148 are legally sustainable when the Assessing Officer obtained… Read More »

Indian Company’s Section 80-IA Infrastructure Exemption Valid; Reopening Beyond Four Years Quashed

By | July 27, 2026
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Indian Company’s Section 80-IA Infrastructure Exemption Valid; Reopening Beyond Four Years Quashed Indian Company’s Section 80-IA Infrastructure Exemption Valid; Reopening Beyond Four Years Quashed Issue Whether reopening an assessment beyond four years under Section 147 to deny Section 80-IA deduction is legally valid when the assessee, an Indian company, fully disclosed all material facts, made… Read More »

Section 80-I Profits Are Computed Without Deducting Section 32AB Allowances for Tax Exemption Purposes

By | July 27, 2026
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Section 80-I Profits Are Computed Without Deducting Section 32AB Allowances for Tax Exemption Purposes Issue Whether, while computing deduction under Section 80-I of the Income-tax Act, 1961, the profits and gains of an industrial undertaking should be taken without reducing the deduction allowable under Section 32AB, in view of Section 80AB. Facts Assessment Year: The… Read More »

Reopening Based on Surmises from Sister Concern’s Survey Evidence Without Direct Proof Is Invalid

By | July 27, 2026
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Reopening Based on Surmises from Sister Concern’s Survey Evidence Without Direct Proof Is Invalid Reopening Based on Surmises from Sister Concern’s Survey Evidence Without Direct Proof Is Invalid Issue Whether a completed assessment under Section 143(3) can be validly reopened under Section 148 based on presumptions and survey findings from a sister concern without any… Read More »

Interest under Section 28 of Land Acquisition Act Forms Part of Compensation, Not Taxable under Income from Other Sources

By | July 27, 2026
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Interest under Section 28 of Land Acquisition Act Forms Part of Compensation, Not Taxable under Income from Other Sources Issue Whether interest received on enhanced compensation under Section 28 of the Land Acquisition Act, 1894 is taxable as ‘Income from Other Sources’ under Section 56(2)(viii) or forms part of the compensation itself. Facts Compulsory Acquisition:… Read More »

Reopening Based Solely on Investigation Reports Without Verification Invalidates Assessment and Deletes Purchase Disallowances

By | July 27, 2026
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Reopening Based Solely on Investigation Reports Without Verification Invalidates Assessment and Deletes Purchase Disallowances Reopening Based Solely on Investigation Reports Without Verification Invalidates Assessment and Deletes Purchase Disallowances Issue Whether an assessment can be validly reopened under Section 148 and purchases treated as bogus when the Assessing Officer acts purely on Investigation Wing inputs without… Read More »

Provisional and Confirmed Benami Attachment Valid Despite Prior PMLA Attachment Due to Non-Disclosure

By | July 27, 2026
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Provisional and Confirmed Benami Attachment Valid Despite Prior PMLA Attachment Due to Non-Disclosure Provisional and Confirmed Benami Attachment Valid Despite Prior PMLA Attachment Due to Non-Disclosure Issue Whether an Initiating Officer can validly pass and continue a provisional attachment under Section 24 of the PBPT Act, 1988, leading to confirmation under Section 26(3), when the… Read More »

Deletions of Notional Rent, Booking Advances, Opening Cash Credit, Bad Debts, Routine Expenses Sustained; Penalty Deferred Pending Writ

By | July 27, 2026
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Deletions of Notional Rent, Booking Advances, Opening Cash Credit, Bad Debts, Routine Expenses Sustained; Penalty Deferred Pending Writ Issue Whether notional rent can be added under Section 22 when rent was received as per a validly executed and active modified rent agreement. Whether booking advances carried forward from prior years or subject to internal transfer… Read More »

Weighted Deduction Under Section 35(2AB) Is Limited to DSIR Approval, but Unapproved Portion Is Deductible Under Section 37(1)

By | July 27, 2026
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Weighted Deduction Under Section 35(2AB) Is Limited to DSIR Approval, but Unapproved Portion Is Deductible Under Section 37(1) Issue Whether an in-house scientific research expenditure disallowed for weighted deduction under Section 35(2AB) due to partial approval by DSIR in Form 3CL is still allowable as a normal business expenditure under Section 37(1). Facts Assessee &… Read More »

Condonation of Delay in Form 10B Granted as Medical Grounds Outweigh Circular Time Limit

By | July 27, 2026
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Condonation of Delay in Form 10B Granted as Medical Grounds Outweigh Circular Time Limit Issue Whether delay in filing the audit report in Form 10B under Section 11 can be condoned under Section 119(2)(b) when supported by genuine medical grounds, despite CBDT Circular No. 16 of 2024 prescribing a three-year time limit. Facts Assessee &… Read More »