Tag Archives: Deputy Commissioner of Income-tax

AIF Investment and Processing Fees Income Cannot Be Arbitrarily Reclassified as Taxable Business Income

By | June 15, 2026
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AIF Investment and Processing Fees Income Cannot Be Arbitrarily Reclassified as Taxable Business Income Issue Whether the Assessing Officer was justified in re-characterizing the interest income, short-term capital gains, and processing fees of a SEBI-registered Category II Alternative Investment Fund (AIF) as business income, thereby denying tax exemption under Section 10(23FBA) read with Section 115UB… Read More »

Donations Sourced From Corporate Social Responsibility Funds Qualification Under Section 80G Are Fully Valid And Omitted Tax Credits Under Section 90 Must Be Factually Restored

By | June 13, 2026
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Donations Sourced From Corporate Social Responsibility Funds Qualification Under Section 80G Are Fully Valid And Omitted Tax Credits Under Section 90 Must Be Factually Restored Donations Sourced From Corporate Social Responsibility Funds Qualification Under Section 80G Are Fully Valid And Omitted Tax Credits Under Section 90 Must Be Factually Restored Issue Whether a company can… Read More »

Corporate Social Responsibility Spend Is Eligible For Section 80G Deductions And Working Capital Adjustments Preclude Separate Interest Imputations On Outstanding Receivables

By | June 13, 2026
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Corporate Social Responsibility Spend Is Eligible For Section 80G Deductions And Working Capital Adjustments Preclude Separate Interest Imputations On Outstanding Receivables Issue Whether Corporate Social Responsibility (CSR) expenditure, which is statutorily disallowed as a business expense under Section 37(1), can be claimed as a deduction under Section 80G if the donation is made to a… Read More »

Alternative Investment Fund’s Exemption Under Section 10(23FBA) Cannot Be Denied By Arbitrarily Reclassifying Investment Returns As Business Income

By | June 13, 2026
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Alternative Investment Fund’s Exemption Under Section 10(23FBA) Cannot Be Denied By Arbitrarily Reclassifying Investment Returns As Business Income Issue Whether the Assessing Officer was justified in re-characterizing an Alternative Investment Fund’s (AIF) interest income, short-term capital gains, and processing fees as business income to deny tax exemption under Section 10(23FBA), without applying settled judicial tests… Read More »

Exempt Investments Without Yield and Section 14A Disallowances Cannot Alter Book Profits or Capital Subsidies

By | June 12, 2026
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Exempt Investments Without Yield and Section 14A Disallowances Cannot Alter Book Profits or Capital Subsidies Issue Issue 1 (Section 14A vs. Rule 8D): Whether investments that did not yield any exempt income during the year can be included in the “average value of investments” for computing disallowance under Rule 8D. Issue 2 (Section 115JB Book… Read More »

Writ Petition Against Jurisdictional Assessing Officer’s Reassessment Disallowed but Remanded to Pending CIT(A) Appeal

By | June 10, 2026
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Writ Petition Against Jurisdictional Assessing Officer’s Reassessment Disallowed but Remanded to Pending CIT(A) Appeal Issue Validity of Notice: Whether the Jurisdictional Assessing Officer (JAO) has the legal authority to initiate reassessment proceedings by issuing a notice under Section 148, and whether subsequent orders can be passed outside the mandatory faceless assessment regime. Maintainability of Writ:… Read More »