No Addition Under Section 69 Or Section 56 Applies When Property Purchases Are Fully Proven Through Banking Channels Issue Whether an addition for unexplained investment under Section 69 read with Section 115BBE can be made when the source of investment in an immovable property is traceable to identified bank accounts and an institutional housing loan.… Read More »
Reassessment Notice Issued Beyond Three Years for Alleged Escaped Income Below Fifty Lakhs Is Time-Barred Reassessment Notice Issued Beyond Three Years for Alleged Escaped Income Below Fifty Lakhs Is Time-Barred Issue Whether reassessment proceedings initiated under Section 148 regarding bogus political party donations are valid when the notice is issued after the three-year limitation period… Read More »
Ex-Gratia Under BSNL Voluntary Retirement Scheme 2019 Qualifies for Exemption Under Section 10(10B) Ex-Gratia Under BSNL Voluntary Retirement Scheme 2019 Qualifies for Exemption Under Section 10(10B) Issue Whether an assessee who opted for the BSNL Voluntary Retirement Scheme, 2019 can claim exemption under Section 10(10B) for ex-gratia compensation before appellate authorities, even if claimed under… Read More »
High Court Declines Parallel Section 154 Writ Intervention But Restrains Coercive Recovery Pending Stay Application Issue Whether the High Court, under its extraordinary writ jurisdiction, should adjudicate a challenge to a Section 154 rectification order when the exact legality and validity of the order is currently pending consideration before the Income Tax Appellate Tribunal (ITAT).… Read More »
ITAT Directs AO to Verify Section 54F Exemption Claim Raised for First Time Before DRP ITAT Directs AO to Verify Section 54F Exemption Claim Raised for First Time Before DRP Issue Whether an additional claim for exemption under Section 54F, raised for the first time before the Dispute Resolution Panel (DRP), should be admitted and… Read More »
Rule 87 Inapplicable for PF Disallowance, Remanded for 43B Verification; Ad-hoc Expenses Disallowance Upheld Issue Rule 87 & PF Disallowance: Whether the Assessing Officer was justified in invoking Rule 87 to disallow employer’s Provident Fund (PF) contributions exceeding 27% of salaries, and whether actual payment under Section 43B required verification. Ad-hoc Expense Disallowance: Whether a… Read More »
Reassessment notices under Section 148 are quashed following Supreme Court precedent in Deepak Steel. Reassessment notices under Section 148 are quashed following Supreme Court precedent in Deepak Steel. Issue Whether the reassessment notices issued to the assessee under Section 148 dated 09.04.2021 and 27.07.2022 for Assessment Year 2015-16 are legally sustainable and valid. Facts Assessment… Read More »
No Section 43CA addition applies to reciprocal exchange of equivalent land for ownership rearrangement. No Section 43CA addition applies to reciprocal exchange of equivalent land for ownership rearrangement. Issue Whether the deeming fiction under Section 43CA of the Income-tax Act, 1961 (Section 53 of the Income-tax Act, 2025) can be invoked for executed sale deeds… Read More »
Maximum Section 271H TDS penalty scaled down to minimum ten thousand per quarter for government institution. Issue Whether levying the maximum penalty of ₹1,00,000 per quarter under Section 271H(1)(a) on a Government educational institution for delayed filing of Form 24Q TDS statements is harsh and unsustainable when deducted tax was timely deposited. Facts Assessee Profile:… Read More »
Rejection of books and unexplained cash additions under Section 69A are unsustainable when turnover is accepted. Rejection of books and unexplained cash additions under Section 69A are unsustainable when turnover is accepted. Issue Whether rejection of books of accounts under Section 145(3) is valid without identifying specific defects or independently estimating business profits, when disclosed… Read More »