Composite Show Cause Notices Covering Multiple Financial Years Are Legally Unsustainable And Must Be Issued Year-Wise

By | July 11, 2026
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Composite Show Cause Notices Covering Multiple Financial Years Are Legally Unsustainable And Must Be Issued Year-Wise Composite Show Cause Notices Covering Multiple Financial Years Are Legally Unsustainable And Must Be Issued Year-Wise Issue Whether the revenue authorities are legally permitted to issue a single, consolidated Show Cause Notice (SCN) and subsequent demand orders under Section… Read More »

Unreasoned Rejection of GST Revocation Application Violates Statutory Rules and Principles of Natural Justice

By | July 11, 2026
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Unreasoned Rejection of GST Revocation Application Violates Statutory Rules and Principles of Natural Justice Unreasoned Rejection of GST Revocation Application Violates Statutory Rules and Principles of Natural Justice Issue Whether the Proper Officer was legally justified in rejecting the petitioner’s registration revocation application through an unreasoned order in Form GST REG-05 solely due to the… Read More »

INCOME TAX CASE LAW 10.07.2026

By | July 11, 2026
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INCOME TAX CASE LAW 10.07.2026 Relevant Act Section Case Law Title Brief Summary Citation Income-tax Act, 1961 Section 2(14) Ketan Pravinchandra Kamdar v. Deputy Commissioner of Income-tax Surrendering an allotment right to a flat constitutes a capital asset; compensation received for its relinquishment is taxable as capital gains, making any resultant long-term capital loss allowable.… Read More »

Rule 257 One-Year Practice Requirement for Income Tax Practitioner Registration is Statutorily Valid and Enforceable

By | July 11, 2026
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Rule 257 One-Year Practice Requirement for Income Tax Practitioner Registration is Statutorily Valid and Enforceable Issue Whether Rule 257 of the Income-tax Rules, 2026, which mandates a minimum of one year of prior appearance/practice before Income Tax Authorities to qualify for registration as an Income Tax Practitioner, is ultra vires or inconsistent with Section 515… Read More »

Refund Adjustments Violating Prior Intimation Rules Cannot Exceed Twenty Percent Limit of Disputed Demands

By | July 11, 2026
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Refund Adjustments Violating Prior Intimation Rules Cannot Exceed Twenty Percent Limit of Disputed Demands Issue Whether the Revenue is legally permitted to adjust subsequent years’ tax refunds against a outstanding disputed demand under Section 245 without issuing prior intimation, and whether an assessee is entitled to a full refund and interest on amounts adjusted in… Read More »

Google AdWords Payments Cover Under Section 194C as Advertising Rather Than Technical Services

By | July 11, 2026
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Google AdWords Payments Cover Under Section 194C as Advertising Rather Than Technical Services Issue Whether payments made to Google India for the Google AdWords program constitute “fees for technical services” under Section 194J requiring human intervention, or are standard advertising contracts subject to tax deduction at source at the lower rate under Section 194C. Facts… Read More »

Assessing Officer of Other Person Must Independently Record Satisfaction Before Overcoming Section 153C Sunset Clause

By | July 11, 2026
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Assessing Officer of Other Person Must Independently Record Satisfaction Before Overcoming Section 153C Sunset Clause Assessing Officer of Other Person Must Independently Record Satisfaction Before Overcoming Section 153C Sunset Clause Issue Whether a Section 153C assessment is legally valid when the Assessing Officer (AO) of the assessee blindly reproduces a forwarding letter from the searched… Read More »

Reopening Barred by Limitation under Section 149 Since Corrected Escaped Income Falls Below Statutory Fifty Lakh Threshold

By | July 11, 2026
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Reopening Barred by Limitation under Section 149 Since Corrected Escaped Income Falls Below Statutory Fifty Lakh Threshold Issue Whether the Assessing Officer was legally justified in issuing a reassessment notice under Section 148 beyond the normal limitation period for an alleged income escape of Rs. 70 lakhs, when a proper evaluation of the transaction records… Read More »

Reassessment Initiated After Dropping Search Proceedings Does Not Bar Relief Under Vivad Se Vishwas Scheme

By | July 11, 2026
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Reassessment Initiated After Dropping Search Proceedings Does Not Bar Relief Under Vivad Se Vishwas Scheme Reassessment Initiated After Dropping Search Proceedings Does Not Bar Relief Under Vivad Se Vishwas Scheme Issue Whether the revenue authorities can integrate dropped Section 153C search proceedings with subsequent Section 147 reassessment proceedings initiated via a Section 133A survey to… Read More »

Unsecured Loan Addition Confirmed Excluding Opening Balance, and Business Loss Set-Off Allowed Prior to 2017

By | July 11, 2026
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Unsecured Loan Addition Confirmed Excluding Opening Balance, and Business Loss Set-Off Allowed Prior to 2017 Issue Whether an addition under Section 68 can be sustained for an unsecured loan when the transaction is conducted via banking channels but cross-verification reveals that the lender did not reflect the receivable in his audited accounts, denied the loan… Read More »