Substantial Compliance over Technical Glitches: Non-Denial of Section 80JJAA Deduction for Delayed Form 10DA

By | May 7, 2026

Substantial Compliance over Technical Glitches: Non-Denial of Section 80JJAA Deduction for Delayed Form 10DA Facts The Claim: The Assessee-company claimed a deduction under Section 80JJAA (relating to the employment of new employees) for the Assessment Year 2023-24. Audit Report: The Assessee obtained the mandatory audit report in Form No. 10DA within the prescribed time limit.… Read More »

Securitisation Trusts are Revocable Trusts: Income Taxable in Hands of SR Holders

By | May 7, 2026

Securitisation Trusts are Revocable Trusts: Income Taxable in Hands of SR Holders Facts The Structure: The Assessee-trust was created by an Asset Reconstruction Company (ARC) under the SARFAESI Act and RBI Guidelines to acquire and realize Non-Performing Assets (NPAs). The Funding: Contributions were received from Qualified Institutional Buyers (QIBs), who were issued Security Receipts (SRs)… Read More »

Section 54F: Eligibility Based on Physical Existence of Residential House vs. Property Classification

By | May 7, 2026

Section 54F: Eligibility Based on Physical Existence of Residential House vs. Property Classification Facts The Transaction: The Assessee, along with co-owners, sold two non-agricultural lands during the financial year relevant to AY 2015-16. The Claim: The sale proceeds were invested in a new residential house, and a deduction was claimed under Section 54F. The Objection:… Read More »

Allowability of Statutory Interest, Cash Payment Limits, and Treatment of Customer Advances

By | May 7, 2026

Allowability of Statutory Interest, Cash Payment Limits, and Treatment of Customer Advances Facts The case involves a company engaged in contract works for power utilities, subjected to a scrutiny assessment for Assessment Year 2018-19. The Revenue challenged the Assessee on three distinct fronts: Statutory Interest: The Assessing Officer (AO) disallowed interest paid on delayed remittances… Read More »

Delayed PF/ESI Deposits Cannot be Disallowed as a ‘Prima Facie’ Adjustment u/s 143(1)

By | May 7, 2026

Delayed PF/ESI Deposits Cannot be Disallowed as a ‘Prima Facie’ Adjustment u/s 143(1) Facts The Dispute: For the Assessment Years 2018-19 to 2020-21, the Assessing Officer (AO) made additions to the total income of the Assessee on account of delayed deposits of employees’ contributions to Provident Fund (PF) and Employee State Insurance (ESI). The Mechanism:… Read More »

Automatic Vacation of Seat vs. Procedural Validity of Meetings under CA Regulations

By | May 7, 2026

Automatic Vacation of Seat vs. Procedural Validity of Meetings under CA Regulations Facts The Petitioner: An elected member of the Northern India Regional Council (NIRC) of the ICAI. The Dispute: The Petitioner received an email on 06-11-2025 stating that his seat was “deemed vacated” under Regulation 135(3) because he had absented himself from three consecutive… Read More »

Scope of Enquiry and Jurisdictional Validity in Renewal of Trust Registration

By | May 7, 2026

Scope of Enquiry and Jurisdictional Validity in Renewal of Trust Registration Facts Background: The Assessee is an educational society originally registered under Section 12AA. Following a search on the group, its registration was cancelled, but the Tribunal later set aside that cancellation. New Scheme Compliance: Under the revamped registration regime, the Assessee obtained provisional/regular registration… Read More »

Revenue Recognition, Real Income, and Admissibility of Business Expenses (Multiple Disputations)

By | May 7, 2026

Revenue Recognition, Real Income, and Admissibility of Business Expenses (Multiple Disputations) Facts The case pertains to Assessment Year 2013-14, involving a construction company and multiple grounds of litigation regarding income characterization and expense allowability. The primary disputes included: Advance Recognition: The Department treated customer advances for land and chalet sales as income because sales weren’t… Read More »