Tag Archives: Deputy Commissioner of Income-tax

Transfer pricing adjustment remanded for fresh evidence verification, while MAT addition on unexpired risks reserve is deleted.

By | August 27, 2026
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Transfer pricing adjustment remanded for fresh evidence verification, while MAT addition on unexpired risks reserve is deleted.   Transfer pricing adjustment remanded for fresh evidence verification, while MAT addition on unexpired risks reserve is deleted. Issue Whether transfer pricing adjustment determining ALP as NIL for intra-group services should be remanded to the AO/TPO to verify… Read More »

Disallowance of depreciation on opening WDV of goodwill and vendor compliance expenses deleted in assessee’s favour.

By | August 27, 2026
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Disallowance of depreciation on opening WDV of goodwill and vendor compliance expenses deleted in assessee’s favour. Issue Whether the Assessing Officer was justified in re-examining and disallowing depreciation on the opening WDV of goodwill by treating its actual cost as nil, despite the issue being settled in the year of amalgamation. Whether the disallowance of… Read More »

Reversal of Unbilled Revenue Offered to Tax and Non-Royalty Payments to Non-Residents Are Deductible

By | August 27, 2026
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Reversal of Unbilled Revenue Offered to Tax and Non-Royalty Payments to Non-Residents Are Deductible Reversal of Unbilled Revenue Offered to Tax and Non-Royalty Payments to Non-Residents Are Deductible Issue Whether the reversal/write-off of opening unbilled revenue that was already offered to tax in preceding assessment years is allowable as business expenditure under Section 37(1). Whether… Read More »

Alleged On-Money Requires Specific Ownership Proof, While WhatsApp Evidence Validates Reduced Section 69A Addition

By | August 22, 2026
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Alleged On-Money Requires Specific Ownership Proof, While WhatsApp Evidence Validates Reduced Section 69A Addition Issue Issue 1 (Section 69 / Section 103): Whether alleged “on-money” recorded in seized electronic files for property purchases can be added as unexplained investment under Section 69 in the hands of an individual whose trade name was listed as a… Read More »

Supreme Court Grants SLP Against High Court Refusal to Quash Prosecution for Belated Return Filing

By | August 21, 2026
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Supreme Court Grants SLP Against High Court Refusal to Quash Prosecution for Belated Return Filing Supreme Court Grants SLP Against High Court Refusal to Quash Prosecution for Belated Return Filing Issue Whether a Special Leave Petition (SLP) should be granted against a High Court judgment that refused to quash Section 276CC criminal prosecution complaints initiated… Read More »

SBI Not Assessee in Default Under Section 201 for Non-Deduction of TDS on Overseas LTC Reimbursements Governed by High Court Stay

By | August 21, 2026
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SBI Not Assessee in Default Under Section 201 for Non-Deduction of TDS on Overseas LTC Reimbursements Governed by High Court Stay SBI Not Assessee in Default Under Section 201 for Non-Deduction of TDS on Overseas LTC Reimbursements Governed by High Court Stay Issue Whether an employer bank can be treated as an assessee in default… Read More »

AO Must Consider Section 170A Modified Return And Cannot Add Transfer Pricing Adjustments To MAT

By | August 20, 2026
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AO Must Consider Section 170A Modified Return And Cannot Add Transfer Pricing Adjustments To MAT Issue Section 170A Modified Return: Whether the Assessing Officer is required to adopt a modified return filed u/s 170A post-NCLT merger scheme as the starting point for recomputing total income. Transfer Pricing Adjustments under MAT: Whether transfer pricing adjustments made… Read More »

ITAT Decides Key Tax Issues On Deductions, Disallowances, Capital Gains, And MAT For AY 2016-17

By | August 20, 2026
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ITAT Decides Key Tax Issues On Deductions, Disallowances, Capital Gains, And MAT For AY 2016-17 Issue Deduction u/s 80-IB/80-IE: Whether interest income from staff advances/deposits and trade receivables is eligible for deduction. Section 14A Disallowance: Whether interest and administrative expense disallowances apply when own interest-free funds are sufficient, and whether Section 14A adjustments apply to… Read More »

Tribunal Cannot Decide Appeal Ex-Parte On Merits Without Verifying Proper Service Of Hearing Notice

By | August 19, 2026
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Tribunal Cannot Decide Appeal Ex-Parte On Merits Without Verifying Proper Service Of Hearing Notice Tribunal Cannot Decide Appeal Ex-Parte On Merits Without Verifying Proper Service Of Hearing Notice Issue Whether the Income Tax Appellate Tribunal (ITAT) can proceed ex-parte and decide an appeal on merits without confirming that a notice of hearing was duly issued… Read More »

Four-Year Delay In Recording Satisfaction Note Invaluates Search Proceedings Under Section 153C

By | August 19, 2026
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Four-Year Delay In Recording Satisfaction Note Invaluates Search Proceedings Under Section 153C Four-Year Delay In Recording Satisfaction Note Invaluates Search Proceedings Under Section 153C Issue Whether initiation of search assessment proceedings under Section 153C against a third party is legally sustainable when there is an unexplained delay of over four years between the search execution… Read More »