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Archive: 30 December 2025

Posts in 30 December 2025

Past U/s 80-IA Relief Doesn’t Guarantee Deduction for New Projects

December 30, 2025 258 Views 0 comment Print

The Tribunal held that deduction under section 80-IA cannot be allowed mechanically based on past relief. Each infrastructure project must be independently examined to determine whether it qualifies as development or is merely a works contract.

Beyond Six Years, Beyond Jurisdiction: Revenue Appeal Fails u/s 153C

December 30, 2025 249 Views 0 comment Print

The ITAT ruled that reassessment under section 153C cannot extend beyond the statutory six assessment years. Jurisdiction assumed outside this period was held void.

SEBI Mandates NISM Certification for AIF Compliance Officers

December 30, 2025 684 Views 0 comment Print

The regulator has introduced a compulsory certification requirement for Compliance Officers of AIF Managers. From January 1, 2027, only NISM Series-III-C certified individuals can hold or continue in this role, strengthening compliance oversight.

Customs Orders Video Recording of Passenger Interactions at Airports

December 30, 2025 837 Views 0 comment Print

Customs officers at international airports must now use BWCs during passenger interactions. The move strengthens transparency and accountability in baggage clearance.

Section 153C Notice Invalid for 22-Month Delay in Recording Satisfaction

December 30, 2025 519 Views 0 comment Print

The Tribunal reaffirmed that satisfaction must be recorded contemporaneously or immediately after the searched person’s assessment. Any belated recording invalidates the assumption of jurisdiction under section 153C.

Reassessment dropped as tax paid on consolidated profit and hence no escapement of income

December 30, 2025 573 Views 0 comment Print

ITAT Rajkot held that there is no escapement of income or loss of revenue since tax paid on the basis of consolidated profit of both the partnership firm and hence reassessment proceedings are not sustainable. Accordingly, appeal of revenue is dismissed.

Presumptive Additions U/s 68 & 69A in Search Cases Quashed

December 30, 2025 318 Views 0 comment Print

The Tribunal ruled that after primary evidence is furnished, the assessee is not required to prove the source of source under section 68, especially where the AO fails to conduct enquiry u/s 131 or 133(6).

Re-agitating same issue which has earlier attained finality is against principles of Res Judicata

December 30, 2025 801 Views 0 comment Print

CESTAT Allahabad held that finding recorded by Commissioner (A) in earlier round of litigation have attained finality. Accordingly, the attempt to re-agitate the same issue in subsequent proceedings is barred by principles of Res Judicata. Accordingly, appeal of department dismissed.

Employee Not Liable for Employer’s Business Expenses

December 30, 2025 237 Views 0 comment Print

The Tribunal deleted additions holding that expenses incurred on behalf of an employer company and recorded in its books cannot be assessed in the employee’s personal assessment.

Ex-Parte Dismissal Without Merits Is Legally Unsustainable

December 30, 2025 258 Views 0 comment Print

The Tribunal held that the first appellate authority has no power to dismiss an appeal merely for non-appearance and must adjudicate issues on merits under section 250(6).

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