Penalty under Section 272A(2)(e) must be restricted to Section 139(4) deadline, not Section 148 return date. Issue Whether penalty under Section 272A(2)(e) for failure to furnish a return of income under Section 139 is to be computed up to the date of filing the return in response to a Section 148 notice, or restricted only… Read More »
Exemption under Section 54/54F is denied when a new residential property is purchased in the wife’s name. Issue Whether an assessee who sells a residential house can claim capital gains exemption under Section 54 or Section 54F of the Income-tax Act, 1961 (corresponding to Sections 82 and 86 of the Income-tax Act, 2025) when the… Read More »
CIT(E) Must Grant Section 12AA Registration for Pre-Amendment Application and Restore Exemption Benefits Issue Whether a registration application validly filed under Section 12AA prior to statutory amendments can be arbitrarily converted by the CIT(E) into a limited-period Section 12AB registration upon remand, and consequently, whether exemption under Sections 11 and 12 can be denied for… Read More »
BSNL VRS-2019 Compensation Is Tax-Exempt Retrenchment Compensation Under Section 10(10B) Of Income-tax Act BSNL VRS-2019 Compensation Is Tax-Exempt Retrenchment Compensation Under Section 10(10B) Of Income-tax Act Issue Whether compensation received by a retired BSNL employee under the BSNL Voluntary Retirement Scheme (VRS-2019) qualifies as tax-exempt retrenchment compensation under Section 10(10B) rather than Section 10(10C) of… Read More »
Delay Condone and TDS Demands/Penalties Deleted as Compliance Followed Judicial Restraint Against LFC Tax Deductions Issue Whether a 131-day delay in filing an appeal can be condoned under Section 253 when caused by e-filing credential issues following centralization, without mala fide intent. Whether an assessee-bank can be treated as an assessee-in-default under Section 201(1)/201(1A) for… Read More »
Unexplained capital introduced in kind attracts Section 68, but proves genuine when inherited or gifted. Unexplained capital introduced in kind attracts Section 68, but proves genuine when inherited or gifted. Issue Whether Section 68 applies to capital introduced into a business by crediting the value of personal jewellery/precious items, and whether the addition made thereunder… Read More »
Reconciliation of BSNL Form 26AS gross receipts with net discount books warrants deleting business income addition. Issue Whether the Assessing Officer was justified in treating the gross amounts reflected in Form 26AS as taxable commission income without considering the trade discount allowed by BSNL, which was netted off in the assessee’s books of account. Facts… Read More »
Corpus donations received with specific directions remain capital receipts and cannot be taxed merely because exemption was claimed under Section 10(23C)(vi) instead of Section 11. Issue Whether voluntary contributions received with a specific direction to form part of the corpus of an educational institution can be treated as taxable income solely because the assessee claimed… Read More »
Reassessment Notice Issued to a Deceased Assessee Is Invalid and Matter Remanded for Fresh Notice to Legal Representatives. Reassessment Notice Issued to a Deceased Assessee Is Invalid and Matter Remanded for Fresh Notice to Legal Representatives. Issue Whether a reassessment notice issued under Section 148 in the name of a deceased assessee is valid, and… Read More »
SBN deposits from loan recoveries explained in books cannot be taxed under Section 68 or denied Section 80P deduction. Issue Whether cash deposits in Specified Bank Notes (SBNs) made by a primary agricultural credit society during demonetization—received towards crop and tractor loan repayments from members—can be added as unexplained cash credit under Section 68 (taxable… Read More »