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Archive: 17 November 2025

Posts in 17 November 2025

External Commercial Borrowings (ECB): Indian & International Perspectives with Legal Analysis

November 17, 2025 1698 Views 0 comment Print

 Summarizes how ECBs are regulated under FEMA and RBI rules, highlighting the proposed market-driven 2025 framework and its impact on borrowers.

Section 54 Exemption on Selling a House: Eligibility, Timelines, Limits and Rules

November 17, 2025 3960 Views 1 comment Print

Breaks down eligibility, timelines, and recent caps, clarifying how Section 54 relief is granted and when it can be withdrawn.

Practical Steps to Prepare a Transfer Pricing Report

November 17, 2025 2937 Views 0 comment Print

Explains the step-by-step TP study process and highlights common documentation, data, and benchmarking challenges, along with what the analysis ultimately held regarding verification requirements.

ITAT: Suspicion Alone Can’t Justify 69A Addition on Agriculturist’s Deposits

November 17, 2025 435 Views 0 comment Print

The Tribunal noted conflicting positions regarding the evidence submitted by the assessee in support of agricultural income. Since the assessment appeared incomplete and lacked thorough verification, the case was returned to the AO. The ruling directs a fair reassessment and deletion of the addition if documentary proof is found satisfactory.

AMP Intensity & BLT Methods Rejected Again; ITAT Deletes Entire AMP Adjustment – Issues Remanded

November 17, 2025 516 Views 0 comment Print

The Tribunal applied long-standing rulings invalidating the intensity and BLT approaches for AMP benchmarking, deleting both substantive and protective adjustments. The decision underscores that such methods lack statutory support.

Section 194-IA TDS Not Triggered for Partial Ownership Below ₹50 Lakh

November 17, 2025 1800 Views 0 comment Print

The ITAT Chandigarh ruled that a co-purchaser of property is not liable to deduct TDS under Section 194-IA if their individual share is below ₹50 lakh, even if total consideration exceeds the limit. The Tribunal quashed both AO and CIT(A) orders.

10(23C)(vi) Exemption Wrongly Denied; Surplus Development Fund Not Proof of Profit Motive

November 17, 2025 1467 Views 0 comment Print

The Tribunal held that use of surplus for land purchase in the society’s name reflects genuine educational intent. It rejected the view that recurring surplus amounts to profit motive and found the earlier inquiry incomplete. The application under Section 10(23C)(vi) was remanded for proper evaluation.

Expenditure on Short-Lived CAD Software Eligible for 80IC Deduction

November 17, 2025 369 Views 0 comment Print

ITAT Chandigarh ruled that CAD software with a short lifecycle and frequent upgrades qualifies as revenue expenditure, enabling full Section 80IC deduction. AO and CIT(A) orders were set aside.

Notification 12/2012-Cus. benefit allowed to Coke Breeze as used for metallurgical purpose only

November 17, 2025 564 Views 0 comment Print

CESTAT Hyderabad held that imported Chinese Coke Breeze used for metallurgical purpose only and not for any other purpose like non-metal extraction, etc. would be entitled to benefit of Notification No.12/2012-Cus dt.17.03.2012. Accordingly, order set aside and appeal allowed.

DRP Wrongly Rejected Vital Evidence; Matter Remanded for Fresh TP Adjudication

November 17, 2025 1620 Views 0 comment Print

The Tribunal held that the DRP erred in refusing to consider the USAID–AE agreement, which directly established the back-to-back cost-plus-6% model. It ruled that such crucial evidence cannot be dismissed on a procedural technicality and remanded the matter for fresh adjudication.

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