Tag Archives: IN THE ITAT AHMEDABAD BENCH

Internal TNMM governs chemical transfer pricing, while additional depreciation applies to storage tanks but is denied for routine spares.

By | June 19, 2026
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Internal TNMM governs chemical transfer pricing, while additional depreciation applies to storage tanks but is denied for routine spares. Issue Whether the tax authorities are legally justified in modifying transfer pricing methods (CUP vs. Internal TNMM), disallowing additional depreciation on plant spares and storage tanks, adjusting book profits under Section 115JB for prior-period expenses, capitalising… Read More »

Section 153A Return Substitutes Section 139 Return, Negating Penalty Under Black Money Act for Omissions in Original Filing

By | June 12, 2026
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Section 153A Return Substitutes Section 139 Return, Negating Penalty Under Black Money Act for Omissions in Original Filing Issue Whether a penalty under Section 43 of the Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015 can be levied for failing to report foreign assets in the original Schedule FA of… Read More »

Digital Evidence Found in Seized Mobile Phones Lacks Statutory Legs Without Strong Corroborative Material

By | June 12, 2026
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Digital Evidence Found in Seized Mobile Phones Lacks Statutory Legs Without Strong Corroborative Material Issue Whether rough electronic notings, WhatsApp chats, unexecuted contract images, or dumb digital documents seized from a mobile phone during a search under Section 132 can form the sole basis for tax additions under Sections 68, 69, 69A, and 69C, or… Read More »