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Archive: May, 2026

Posts in May, 2026

Abandoned Software Development Costs Allowed as Revenue Expense in Adadyn Technologies Case

May 14, 2026 108 Views 0 comment Print

The article explains how the ITAT allowed deduction of abandoned software project costs as revenue expenditure. The ruling clarifies that no capital asset arises when a project is permanently abandoned.

Dividend from Foreign Subsidiaries: Taxation & Section 80M Interplay

May 14, 2026 201 Views 0 comment Print

The article explains how Section 80M applies only to domestic dividends, leaving foreign subsidiary dividends fully taxable in India. This creates economic double taxation for Indian parent companies.

Interest on Broken Periods for Banks – Revisiting SC’s 2024 Ruling (Bank of Rajasthan)

May 14, 2026 159 Views 0 comment Print

The article explains the Supreme Court’s landmark 2024 ruling that broken period interest on debt securities is capital in nature. The judgment rejects the Revenue’s attempt to tax such receipts as interest income.

Diminishing Role of “Tax Planning” in New Concessional Regimes – Is Optimization Now Dead?

May 14, 2026 141 Views 0 comment Print

The article explains how Sections 115BAA, 115BAB, 115BAC, and 115BAE have reduced the importance of traditional deduction-based tax planning. It highlights the shift toward strategic and substance-driven tax optimization.

Decoding Section 115BAE: Are Co-operative Societies Next Manufacturing Hubs?

May 14, 2026 216 Views 0 comment Print

The article explains how Section 115BAE offers newly established co-operative societies a concessional 15% tax rate for manufacturing activities. It highlights the provision’s potential to transform co-operatives into industrial growth engines.

GST Insight Portal Mismatch Alone Cannot Justify Section 263 Revision

May 14, 2026 660 Views 0 comment Print

The ITAT Surat held that revision under Section 263 was invalid because the Assessing Officer had already conducted inquiries and examined relevant records. Mere discrepancies in Insight Portal GST data were held insufficient to render the assessment order erroneous.

ITAT Sends Back Bogus Purchase & Cash Credit Additions for Fresh Decision

May 14, 2026 399 Views 0 comment Print

ITAT Surat restored reassessment appeals to the CIT(A) after observing that the assessee should receive one final opportunity to present evidence. The Tribunal imposed costs due to partial compliance before the appellate authority.

ITAT Orders Exclusion of Comparable as DRP Had Already Held It Functionally Different

May 14, 2026 459 Views 0 comment Print

Delhi ITAT directed exclusion of a comparable company engaged in video conferencing solutions after noting that the DRP had already found it functionally incomparable to the assessee’s software distribution business.

ITAT Restricts Section 14A Disallowance as It Cannot Exceed Exempt Income

May 14, 2026 360 Views 0 comment Print

Lucknow ITAT held that disallowance under Section 14A read with Rule 8D cannot exceed the exempt dividend income earned by the assessee. The Tribunal restricted the addition to the actual exempt income amount.

ITAT Remands Bogus Purchase Case as Rice Miller Issue Is Pending Before HC

May 14, 2026 321 Views 0 comment Print

The Tribunal held that the first appellate authority should reconsider the matter after the jurisdictional High Court decides pending cases concerning alleged bogus purchase bills by rice millers.

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