Charge over Seized Cash Extinguishes Once Searched Person’s Assessment Concludes, Entitling Assessee to Refund Credit

By | September 9, 2026
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Charge over Seized Cash Extinguishes Once Searched Person’s Assessment Concludes, Entitling Assessee to Refund Credit Charge over Seized Cash Extinguishes Once Searched Person’s Assessment Concludes, Entitling Assessee to Refund Credit Issue Whether, after the assessment of the searched person was completed with no demand, the Department’s charge over seized cash under Section 132B stood extinguished,… Read More »

Institutions with religious activities qualify for Section 80G registration if religious expenditure is under 5%.

By | September 9, 2026
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Institutions with religious activities qualify for Section 80G registration if religious expenditure is under 5%. Issue Whether an institution engaged in religious activities remains eligible for approval under Section 80G if its religious expenditure does not exceed 5% of its total income pursuant to the deeming fiction under Section 80G(5B) [Section 133 of Income-tax Act,… Read More »

Addition under Section 69A for repaid prior-year loan routed through banking channels is unsustainable.

By | September 9, 2026
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Addition under Section 69A for repaid prior-year loan routed through banking channels is unsustainable. Addition under Section 69A for repaid prior-year loan routed through banking channels is unsustainable. Issue Whether an addition under Section 69A can be sustained as unexplained money on account of alleged bogus accommodation entries when the loan was actually received in… Read More »

Addition under Section 56(2)(vii)(b) is unsustainable when Permanent Alternate Accommodation is granted against relinquishing sub-tenancy rights without receipt of possession.

By | September 9, 2026
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Addition under Section 56(2)(vii)(b) is unsustainable when Permanent Alternate Accommodation is granted against relinquishing sub-tenancy rights without receipt of possession. Issue Whether an addition under Section 56(2)(vii)(b) can be sustained when the assessee acquired entitlement to Permanent Alternate Accommodation (PAA) directly in consideration for relinquishing existing sub-tenancy/occupancy rights under a redevelopment agreement, and where physical… Read More »

Addition for unexplained loan deleted as identity proven, while undervaluation matter remanded for agreement verification.

By | September 9, 2026
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Addition for unexplained loan deleted as identity proven, while undervaluation matter remanded for agreement verification. Issue Unexplained Investments (Section 69): Whether an addition made by the AO under Section 69 on account of an unexplained loan investment is liable to be deleted when the assessee furnished the lender’s PAN, loan confirmation letter, and bank statements… Read More »

EPF/ESI delayed by web portal technical glitches is deductible under Section 36(1)(va).

By | September 9, 2026
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EPF/ESI delayed by web portal technical glitches is deductible under Section 36(1)(va). Issue Whether a one-day delay in remitting employee EPF/ESI contributions due to technical glitches and non-availability of the payment gateway/EPFO web portal beyond the assessee’s control constitutes a violation of Section 36(1)(va) disallowing the deduction. Facts Assessee & Assessment Year: The assessee is… Read More »

Registration under Section 12AB cannot be cancelled absent proof of non-genuine activities or statutory violations.

By | September 9, 2026
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Registration under Section 12AB cannot be cancelled absent proof of non-genuine activities or statutory violations. Issue Whether CIT(E) can cancel an educational trust’s Section 12AB registration over bank cash deposits, high surplus ratios, or unrecorded leases without proving non-genuine activities or fund diversion. Facts Registration Granted: The assessee-society, running educational institutions, was granted registration under… Read More »

Reversal write-backs, foreign exchange losses, and secondment reimbursements are non-taxable, while transfer pricing adjustments require re-examination.

By | September 9, 2026
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Reversal write-backs, foreign exchange losses, and secondment reimbursements are non-taxable, while transfer pricing adjustments require re-examination. Issue Whether capacity utilization/economic adjustments under TNMM can be summarily rejected by the TPO without considering past coordinate bench precedents. Whether provisions created in earlier years and treated as operating expenses can be treated as non-operating income upon write-back… Read More »