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Archive: 04 November 2025

Posts in 04 November 2025

ITAT Delhi Allows Adjustment of Seized Cash Against Self-Assessment Tax

November 4, 2025 918 Views 0 comment Print

ITAT Delhi held that cash seized during search operations can be adjusted against self-assessment tax. The order distinguishes between advance tax and self-assessment tax, directing deletion of demand raised by CPC.

Reassessment Quashed as Section 148 Notice Issued Before Mandatory Approval

November 4, 2025 357 Views 0 comment Print

The ITAT Delhi invalidated reassessment proceedings because the Section 148 notice was issued two days prior to obtaining the mandatory statutory sanction under Section 151 from the Additional Commissioner. The Tribunal held that obtaining the requisite approval is a precondition for valid reopening, and issuing the notice before approval renders the entire action void ab initio.

On-Money Addition Reduced by 70% as Only Profit Element is Taxable: ITAT Rajkot

November 4, 2025 321 Views 0 comment Print

The ITAT Rajkot significantly reduced an addition made under Section 69, ruling that in cases of alleged “on-money” payments found during a search, only the embedded profit component is taxable. Following the Gujarat High Court precedent, the Tribunal restricted the unexplained investment addition of Rs.1.25 lakh to just 30% (Rs.37,500).

DIN in CGST/Income Tax: An emerging area of dispute

November 4, 2025 651 Views 0 comment Print

Tax notices lacking a mandatory DIN were deemed void by courts, citing CBIC/CBDT circulars. The Supreme Court has stayed these rulings, creating uncertainty over DIN compliance.

ODI under Automatic Route vs Approval Route – Practical Insights

November 4, 2025 1524 Views 0 comment Print

Summarizing RBI’s New OI Regime (FEMA 2022) for Overseas Direct Investment. Key limits, mandatory reporting (UIN, APR, FLA), and when to use the Automatic or Approval Route.

Groww IPO: A Landmark Moment in India’s ESOP Evolution

November 4, 2025 819 Views 0 comment Print

Groww’s IPO (Nov 4-7, 2025) will unlock ₹2,500 crore in employee ESOP wealth. The event signals the maturation of the ESOP ecosystem, driving talent retention and wealth creation in Indian tech.

Share Premium Tax Addition Remanded for Selective Evidence Acceptance

November 4, 2025 375 Views 0 comment Print

The ITAT Delhi set aside a Section 56(2)(viib) addition, ruling that the CIT(A) acted improperly by selectively accepting valuation evidence for one issue (Sec. 68) but rejecting it for the share premium issue. The matter was remanded for a fresh review of the valuation evidence, establishing that all relevant material must be considered fairly.

Penalty was quashed as Revenue could not treat sale price as ‘Tax Inclusive’ without Proof

November 4, 2025 294 Views 0 comment Print

Penalty of Rs. 25.53 Cr. on Hindustan Coca-Cola was quashed as assessee had not collected any amount by way of sales tax during the exemption period, and the Revenue’s assumption of implicit tax collection was unsustainable.

CBIC Notifies Voluntary Post-Clearance Customs Revision Regulations

November 4, 2025 2109 Views 0 comment Print

CBIC allows voluntary post-clearance revision of Bill of Entry/Shipping Bills via new regulations (Sec 18A). Importers and exporters can correct errors; Rs.1,000 fee applies.

Role of Education and Skill Development in Prisoner Rehabilitation

November 4, 2025 321 Views 0 comment Print

Learn how academic and vocational training programs in Indian prisons help transform offenders, reduce recidivism, and facilitate their reintegration into society after re-lease.

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