Interest on Borrowings for Acquiring NCDs Includible in Cost of Acquisition for Capital Gains Computation Issue Whether interest paid on borrowed funds utilized for acquiring Non-Convertible Debentures (NCDs) forms an integral part of the cost of acquisition for computing capital gains under Section 48 of the Income-tax Act, 1961 (Section 69 of the Income-tax Act,… Read More »
Failure To Grant Requested Personal Hearing Under Section 148A Vitiates Reassessment Order Requiring Fresh Opportunity Issue Whether passing an order under Section 148A(3) without granting a personal hearing, despite a specific request by the assessee, violates principles of natural justice and invalidates the order. Whether the Assessing Officer is permitted to proceed afresh under Section… Read More »
Berry Ratio Unsuitable For Manufacturers And Interest Imputed Only On Differential Credit Period Delays Issue Whether the Berry ratio (Operating Profit / Value Added Expenses) under TNMM is an appropriate Profit Level Indicator (PLI) for benchmarking international transactions of an entity with a full-fledged manufacturing profile. Whether interest can be imputed on delayed receivables from… Read More »
Declaration Under Vivad Se Vishwas Scheme Covers Only Original Assessment, While Reassessment Addition Made Without Details Is Void Issue Whether a settlement declaration filed under the Direct Tax Vivad Se Vishwas Act, 2020 with respect to an original assessment order under Section 143(3) also covers additions made in subsequent reassessment proceedings under Section 147? Whether… Read More »
Exemption from deduction of tax at source in respect of interest payable under the New Development Bank (NDB) Maharajah INR Bond Programme. The Gazette of India CG-DL-E-19102026-277283 EXTRAORDINARY PART II—Section 3—Sub-section (ii) PUBLISHED BY AUTHORITY No. 5477] NEW DELHI, MONDAY, OCTOBER 19, 2026/ASVINA 27, 1948 MINISTRY OF FINANCE (Department of Revenue) (CENTRAL BOARD… Read More »
Appellate authority cannot convert misreporting penalty to under-reporting penalty when misreporting charge fails. Appellate authority cannot convert misreporting penalty to under-reporting penalty when misreporting charge fails. Issue Whether penalty for under-reporting in consequence of misreporting under Section 270A(8)/270A(9) can be sustained when none of the specific limb conditions under sub-section (9) are satisfied. Whether an… Read More »
Revisional Order Under Section 263 Invalid as Interest Under Section 28 Land Acquisition Act Forms Exempt Compensation Issue Whether interest received under Section 28 of the Land Acquisition Act, 1894 forms part of compensation exempt under Section 10(37), and whether the PCIT/CIT can invoke revision under Section 263 where the Assessing Officer accepted the claim… Read More »
INCOME TAX CASE LAWS 03.10.20226 Section Case Law Title Brief Summary Citation Relevant Act N/A CBDT Notification Amendment CBDT amended Notification dated March 30, 1988 (substituting clause (ba)) placing Joint Commissioners of Income-tax (Appeals) and Additional Commissioners of Income-tax (Appeals) under the jurisdiction of the respective Pr. CCITs/CCITs within whose jurisdiction they function. Click… Read More »
Capital gains tax cannot be levied under Section 2(47) without verifying whether the assessee was a power-of-attorney holder or the actual landowner. Issue Whether long-term capital gains under Section 2(47) can be assessed in the hands of an assessee under a Joint Development Agreement without verifying whether he acted merely as a power-of-attorney holder/agent rather… Read More »
Addition Under Section 69A Unjustified When Bank Credit Source Is Proven And Uncorroborated Cash Receipts Unproven Addition Under Section 69A Unjustified When Bank Credit Source Is Proven And Uncorroborated Cash Receipts Unproven Issue Whether an addition under Section 69A for unexplained money can be sustained for AY 2019-20 when a bank credit of Rs. 11… Read More »