Tag Archives: Deputy Commissioner of Income-tax

Tax Computation Sheet Must Align With Assessment Order And Secondary Adjustment Requires Associated Enterprise Relationship

By | October 27, 2026
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Tax Computation Sheet Must Align With Assessment Order And Secondary Adjustment Requires Associated Enterprise Relationship Issue Whether the tax computation sheet, as a consequential document forming part of assessment proceedings, can proceed on an assessed income contrary to the income determined in the main assessment order. Whether the Resale Price Method (RPM) is the appropriate… Read More »

Separate Events Cannot Be Aggregated Under Section 149(1A) Making Reassessment Beyond Threshold Invalid

By | October 27, 2026
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Separate Events Cannot Be Aggregated Under Section 149(1A) Making Reassessment Beyond Threshold Invalid Issue Whether cash payments made on different dates against distinct orders constitute separate events that cannot be aggregated under Section 149(1A) to meet the ₹50 lakh threshold for reassessment beyond three years. Whether reassessment proceedings under Section 148 initiated for Assessment Year… Read More »

Unaccounted Stock Commingled with Business Inventory Is Business Income, While Unreconciled Excess Cash Remains Unexplained Money

By | October 26, 2026
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Unaccounted Stock Commingled with Business Inventory Is Business Income, While Unreconciled Excess Cash Remains Unexplained Money Issue Whether excess physical stock of traded goods found during a survey and commingled with regular inventory should be assessed as business income or as unexplained investment under Section 69, and whether Section 115BBE applies? Whether unreconciled excess cash… Read More »

Reassessment Without Pre-Notice Information and Section 56(2)(x) Tax on Proportionate Rights Shares Are Invalid

By | October 26, 2026
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Reassessment Without Pre-Notice Information and Section 56(2)(x) Tax on Proportionate Rights Shares Are Invalid Issue Whether a reassessment notice issued under Section 148A without disclosing the material information forming the basis of alleged escapement can be cured by supplying information after the Section 149 limitation period has expired? Whether the difference between the fair market… Read More »

Gross movement of third-party funds in Angadia business cannot be added as unexplained cash; only realistic commission is taxable.

By | October 21, 2026
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Gross movement of third-party funds in Angadia business cannot be added as unexplained cash; only realistic commission is taxable. Issue Whether gross principal amounts recorded in seized notebooks and mobile data of an Angadia operator represent undisclosed income under section 69A, or merely third-party funds transmitted in the ordinary course of business. Whether an ad-hoc… Read More »

TP Adjustments Under Omitted Section 92BA(i) Disallowed, MTM Losses Allowed, and Section 14A Disallowance Restricted

By | October 21, 2026
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TP Adjustments Under Omitted Section 92BA(i) Disallowed, MTM Losses Allowed, and Section 14A Disallowance Restricted Issue Issue I (Transfer Pricing – Specified Domestic Transactions): Whether transfer pricing adjustments made under clause (i) of Section 92BA are liable to be deleted following its omission by the Finance Act, 2017. Issue II (Business Expenditure – Mark-to-Market Loss):… Read More »

Transporter TDS Exemption Declarations and Form 26A Physical Filingcs Require Detailed Verification Upon Remand

By | October 17, 2026
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Transporter TDS Exemption Declarations and Form 26A Physical Filingcs Require Detailed Verification Upon Remand Issue Validity of Section 194C(6) Declarations: Whether a transporter declaration lacking specific freight details or registration numbers can be rejected without confronting the assessee with discovered discrepancies, or solely because it is not formatted as per Circular No. 19/2015. Acceptance of… Read More »

Reassessment Quashed as Same Additions Were Pending Adjudication Before High Court

By | October 17, 2026
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Reassessment Quashed as Same Additions Were Pending Adjudication Before High Court Issue Whether the Revenue can validly initiate reassessment proceedings under Section 148 and pass a consequential reassessment order under Section 147 in respect of additions that were previously adjudicated and are currently pending determination before the High Court in tax appeals. Facts Search &… Read More »

Addition Under Section 68 Unjustified as Demonetization Cash Deposits Were Supported by Verified Bullion Sales

By | October 17, 2026
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Addition Under Section 68 Unjustified as Demonetization Cash Deposits Were Supported by Verified Bullion Sales Issue Whether cash deposits made during the demonetization period out of recorded bullion and jewellery sales can be treated as unexplained cash credit under Section 68 read with Section 115BBE when stock records, purchases, and sales remain undisputed. Facts Business… Read More »

Interim Board Settlement Applications Valid If Live Assessment Notice Pending On Filing Date

By | October 16, 2026
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Interim Board Settlement Applications Valid If Live Assessment Notice Pending On Filing Date Issue Whether the Interim Board for Settlement can reject a settlement application filed on or before September 30, 2021, on the ground that no assessment proceeding was pending as on January 31, 2021, even though the assessee held a live and unadjudicated… Read More »