Tag Archives: DCIT

Revenue cannot force POCM over consistently accepted Project Completion Method, nor make additions for interest-free advances backed by own interest-free funds.

By | June 19, 2026

Revenue cannot force POCM over consistently accepted Project Completion Method, nor make additions for interest-free advances backed by own interest-free funds. Issue Whether the tax authorities can unilaterally replace an consistently followed Project Completion Method with the Percentage of Completion Method (POCM), disallow interest under Section 36(1)(iii) despite the availability of interest-free funds, invoke Section… Read More »

ESOP discount is an ascertained business expenditure under Section 37(1), and no Section 14A disallowance can be made if no exempt income is earned.

By | June 19, 2026

ESOP discount is an ascertained business expenditure under Section 37(1), and no Section 14A disallowance can be made if no exempt income is earned. Issue Whether the discount on the issuance of Employee Stock Option Plans (ESOPs) is an allowable business expenditure under Section 37(1) rather than a national or contingent liability, and whether a… Read More »

Reassessment Issued by an Officer Lacking Pecuniary Jurisdiction Under CBDT Instructions Is Void and Liable to Be Quashed

By | June 18, 2026

Reassessment Issued by an Officer Lacking Pecuniary Jurisdiction Under CBDT Instructions Is Void and Liable to Be Quashed Issue Whether a reassessment notice under Section 148 and the consequential assessment order are legally valid if they are issued by an Assistant Commissioner of Income Tax (ACIT) who lacks the pecuniary jurisdiction specified under binding CBDT… Read More »