Disallowance of unsubstantiated marketing expenses is restricted to Rs. 5 lakhs, and Section 270A penalty is deleted. Issue Whether the complete disallowance of marketing expenses supported only by self-made vouchers is justified under Section 37(1) of the Income-tax Act, 1961 / Section 34 of the Income-tax Act, 2025, when the expenditure is reasonable relative to… Read More »
Ex-gratia payment under BSNL VRS-2019 qualifies as retrenchment compensation fully exempt under Section 10(10B). Ex-gratia payment under BSNL VRS-2019 qualifies as retrenchment compensation fully exempt under Section 10(10B). Issue Whether ex-gratia compensation received by a retired BSNL employee under the BSNL VRS-2019 is eligible for exemption as retrenchment compensation under Section 10(10B) rather than being… Read More »
Providing transportation services on commercial lines to school students does not constitute charitable purpose under section 2(15). Issue Whether an institution providing student transport services on commercial lines against a fee, generating recurring surpluses, is entitled to regular registration under Section 12AB as a charitable entity under Section 2(15) of the Income-tax Act, 1961 /… Read More »
Reassessment Order Issued Beyond Three Years Without Higher Authority Approval Under Section 151 Is Void Issue Whether the time allowed to an assessee under Section 148A(b) can be excluded while computing the three-year limitation period under Section 151. Whether a reassessment notice under Section 148 issued beyond three years with approval from the PCIT instead… Read More »
Section 80GGC Deduction Disallowed as Political Donation Was a Non-Genuine Accommodation Entry Scheme Issue Whether a salaried employee is entitled to a deduction under Section 80GGC for a donation made to a political party when independent search findings establish that the donee entity operated as a conduit for providing bogus accommodation entries. Facts Deduction Claimed:… Read More »
Reassessment Order Quashed as Assessing Officer Made No Addition on Reasons Recorded for Reopening Issue Whether a reassessment order passed under Section 147 is valid when the Assessing Officer makes additions on an entirely different ground (unexplained money under Section 69A) while making no addition on the specific ground for which the assessment was reopened… Read More »
Manipulated derivative trading losses from illiquid stock options are non-deductible, while reopening approval jurisdiction requires CIT(A) re-examination. Issue Whether losses generated from trading in illiquid stock option derivatives constitute genuine business losses allowable under Section 28(i) or pre-arranged, fictitious losses. Whether the reassessment proceedings under Section 147/148 were invalid due to procedural non-compliance under Section… Read More »
Rectification order passed beyond four years without notice and DIN is invalid and barred by limitation Issue Whether a rectification order passed under section 154 read with section 143(3) beyond four years from the end of the financial year in which the original assessment order was passed is barred by limitation. Whether a section 154… Read More »
Section 80GGC Deduction Disallowed as Donation to Political Party Was Fake Accommodation Entry Issue Whether a claim for deduction under section 80GGC for a donation made to a registered unrecognized political party can be disallowed under section 148 reassessment when investigation material demonstrates that the contribution was a non-genuine accommodation entry. Facts The assessee claimed… Read More »
Additions under Sections 69A and 56(2)(x) are unsustainable when consideration is adjusted against prior mortgage liabilities, guideline values are disputed without independent evidence, and cash deposit explanations are rejected without objective verification. Additions under Sections 69A and 56(2)(x) are unsustainable when consideration is adjusted against prior mortgage liabilities, guideline values are disputed without independent evidence,… Read More »