Tag Archives: ACIT

Enhanced compensation for agricultural land is exempt and recharacterization of capital gains is valid.

By | September 4, 2026
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Enhanced compensation for agricultural land is exempt and recharacterization of capital gains is valid. Enhanced compensation for agricultural land is exempt and recharacterization of capital gains is valid. Issue Whether enhanced compensation received for compulsory acquisition of agricultural land qualifies for exemption under Section 10(37), and whether an inadvertent classification of Long-Term Capital Gains as… Read More »

Foreign Currency Loans Benchmark via LIBOR, Dissimilar Comparables Excluded, and Receivables Notional Interest Deleted

By | September 3, 2026
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Foreign Currency Loans Benchmark via LIBOR, Dissimilar Comparables Excluded, and Receivables Notional Interest Deleted Foreign Currency Loans Benchmark via LIBOR, Dissimilar Comparables Excluded, and Receivables Notional Interest Deleted Issue Whether, for Assessment Year 2013-14: Benchmarking of interest on foreign currency loans to AEs should be based on LIBOR plus spread rather than SBI PLR. Under… Read More »

Reassessment Under Section 148 Is Invalid Post Section 132A Requisition When Section 153A Limitation Expires

By | September 2, 2026
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Reassessment Under Section 148 Is Invalid Post Section 132A Requisition When Section 153A Limitation Expires Issue Whether, in a case where cash is requisitioned under Section 132A, the Assessing Officer can initiate reassessment proceedings under Section 148 read with Section 148A after failing to initiate search assessment proceedings under Section 153A within the prescribed limitation… Read More »

Section 115BBE Cannot Be Invoked Without Specific Findings and Addition Under Sections 68 to 69D

By | September 1, 2026
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Section 115BBE Cannot Be Invoked Without Specific Findings and Addition Under Sections 68 to 69D Issue Whether Section 115BBE can be invoked to tax surrendered income at higher rates without the Assessing Officer invoking or recording specific findings under any of Sections 68 to 69D, and without making any addition over returned income. Facts The… Read More »

Bad Debt Claims, MAT Credit Corrections, and Rectification Orders Remanded for Verification and Natural Justice

By | August 29, 2026
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Bad Debt Claims, MAT Credit Corrections, and Rectification Orders Remanded for Verification and Natural Justice Issue Whether the write-off of advances, correction of MAT credit without a revised return, and ex-parte rectification orders adding FTS disallowances require factual verification and adherence to natural justice. Facts Bad Debts/Advances Write-off: For AY 2011-12, the assessee (an automotive… Read More »

Revision Under Section 263 Invalid as Assessing Officer Adopted Possible View Granting Assessee’s Loss Claim

By | August 28, 2026
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Revision Under Section 263 Invalid as Assessing Officer Adopted Possible View Granting Assessee’s Loss Claim Issue Whether the PCIT can exercise revisionary jurisdiction under Section 263 to set aside a completed assessment for fresh inquiry when the Assessing Officer has already taken a plausible view allowing a business loss claim supported by ITAT precedent. Facts… Read More »

Assessment Remanded to Re-examine Capital Gains Documents Pertaining to Sold Immovable Properties

By | August 22, 2026
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Assessment Remanded to Re-examine Capital Gains Documents Pertaining to Sold Immovable Properties Assessment Remanded to Re-examine Capital Gains Documents Pertaining to Sold Immovable Properties Issue Whether an assessment addition under Section 69 of the Income-tax Act, 1961 (Section 103 of the Income-tax Act, 2025) for unexplained investment/undisclosed capital gains should be restored to the Assessing… Read More »

Exemption applies to agricultural land sold beyond specified municipal limits, making capital gains non-taxable under Section 2(14).

By | August 22, 2026
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Exemption applies to agricultural land sold beyond specified municipal limits, making capital gains non-taxable under Section 2(14). Issue Whether capital gains tax is applicable on the sale of agricultural land situated beyond the prescribed statutory distance from municipal boundaries under Section 2(14) of the Income-tax Act. Facts The assessee transferred a parcel of agricultural land… Read More »

Customary household savings, gifts, and past family cash inflows explain cash found during search, invalidating Section 69A addition.

By | August 21, 2026
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Customary household savings, gifts, and past family cash inflows explain cash found during search, invalidating Section 69A addition. Issue Whether cash of Rs. 8.87 lakhs attributed to a senior citizen mother and minor children can be added as unexplained money under Section 69A when supported by customary household savings, traditional gifts, and documented past cash… Read More »

Repayment of unsecured loans prior to assessment completion proves genuineness, rendering Section 68 addition and interest disallowance unsustainable.

By | August 21, 2026
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Repayment of unsecured loans prior to assessment completion proves genuineness, rendering Section 68 addition and interest disallowance unsustainable. Issue Whether an addition under Section 68 toward unexplained cash credits and consequential interest disallowance can be sustained when the unsecured loans received from lenders were fully repaid prior to the completion of the assessment. Facts Assessee,… Read More »