Rental income applied to charitable objects and reasonable CEO remuneration do not forfeit trust exemption. Issue Rental Income & Commercial Activity: Whether a charitable trust forfeits exemption under Sections 11 and 12 when it earns substantial rental income by leasing trust property, where such leasing is empowered by the trust deed and the receipts are… Read More »
Section 153C assessments are quashed because satisfaction notes recorded post-April 1, 2021, render proceedings non-est and time-barred. Issue Whether the assessment orders passed under Section 153C for AY 2015-16, 2016-17, and 2017-18 are legally sustainable when the mandatory satisfaction note was recorded on October 11, 2022 (Financial Year 2022-23), shifting the statutory block period and… Read More »
Valid Advance Pricing Agreements bind the Revenue, precluding alternative business expenditure disallowances under Section 37(1). Issue Whether the tax department can alternatively disallow an expenditure under Section 37(1) of the Income-tax Act after the underlying international transaction has already been covered, verified, and accepted under a binding Advance Pricing Agreement (APA) under Section 92CC. Facts… Read More »
Reassessment Initiated Beyond Three Years Without Tangible Material Indicating Escapement of Fifty Lakhs or More Is Void Issue Whether a reassessment notice issued under Section 148 for the Assessment Year 2015-16 is legally sustainable if it is issued beyond the standard three-year limitation period from the end of the relevant assessment year without any material… Read More »
Reassessment Notices Issued Beyond Three Years Without Material Proving Escapement of Fifty Lakhs or More Are Void Issue Whether a reassessment notice under Section 148 for the Assessment Year 2015-16, issued in January 2026, is legally valid under the amended provisions of Section 149 if the Revenue fails to demonstrate that the income escaping assessment… Read More »