Additional Evidence on Transfer Pricing and Enhanced Gross Income Merit Re-evaluation of Deductions Additional Evidence on Transfer Pricing and Enhanced Gross Income Merit Re-evaluation of Deductions Issue Whether a Transfer Pricing Officer (TPO) can sustain an Arm’s Length Price (ALP) of “Nil” for IT services once the assessee submits fresh, comprehensive cost allocation and service… Read More »
Taxing Gross Online Gaming Winnings Without Offsetting Associated Entry Costs and Losses Is Impermissible Taxing Gross Online Gaming Winnings Without Offsetting Associated Entry Costs and Losses Is Impermissible Issue Whether income from online games under Section 115BB must be computed on the basis of “net winnings” by offsetting entry costs and losses, or on the… Read More »
Demonetization Cash Deposits Supported by Valid Marriage Gifts and Savings Cannot Be Treated as Unexplained Issue Whether cash deposits made by a salaried individual during the demonetization period can be treated as unexplained money under Section 69A and taxed under Section 115BBE, when the source is attributed to marriage gifts, household savings, and medical contingency… Read More »
Reassessment Is Invalid If Reasons Are Not Supplied And The Underlying Admission Was Retracted Issue Whether a reassessment under Section 147/148 is legally sustainable when the Revenue fails to supply the complete recorded reasons to the assessee and relies solely on a director’s statement that had been fully retracted prior to the issuance of the… Read More »
Assessing Officer Cannot Reject Registered Valuer’s Improvement Cost Report Without Referencing Valuation Officer Issue Whether the Assessing Officer is legally justified in completely rejecting a registered valuer’s report and treating the cost of property improvement as nil due to a lack of decades-old documentary evidence, without making a statutory reference to the Departmental Valuation Officer… Read More »
Section 80G and 80JJAA Deductions Allowed; Platform Enhancement and Delayed Form 67 Procedural Defect Resolved Issue Whether a deduction under Section 80G can be denied solely because the underlying donation forms a part of the company’s mandatory Corporate Social Responsibility (CSR) expenditure. Whether a legitimate claim for Foreign Tax Credit (FTC) can be rejected purely… Read More »
No Penalty for Concealment Can Be Levied When Returned Interest Income Is Accepted Without Additions Issue Whether a penalty for concealment of chargeable interest or furnishing inaccurate particulars under Section 13 of the Interest Tax Act, 1974 can be legally sustained when the Assessing Officer accepts the assessee’s filed returns without making any additions or… Read More »
Rectification of Procedural Defect in Form 10AB Relates Back to Timely Filed Original Application Rectification of Procedural Defect in Form 10AB Relates Back to Timely Filed Original Application Issue Whether a subsequent application in Form No. 10AB, filed under the correct statutory sub-clause to rectify an inadvertent error in the original timely application, can be… Read More »
Notification F. NO. 225/73/2025-ITA-II, Dt 08-07-2026 Notification F. NO. 225/73/2025-ITA-II, Dt 08-07-2026 F.No. 225/73/2025–ITA–II Government of India Ministry of Finance Department of Revenue Central Board of Direct Taxes 10018, Kartavya Bhawan- 01 New Delhi, dated the 8 July, 2026 ORDER In exercise of powers conferred under section 119 of the Income–tax Act, 1961 (‘the Act‘)… Read More »
No Disallowance Under Section 40(a)(i) if Technical Services Are Not Made Available to the Assessee Issues Whether payments to US non-resident contractors for software services are taxable as “Fees for Included Services” under the India-USA DTAA if the “make available” condition is not satisfied. Whether payments to a UK entity for a website access license… Read More »