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Income Tax : The article explains how the Finance Acts, 2025 and 2026 have reshaped the Updated Return regime under Section 139(8A). It highlig...
Income Tax : The Supreme Court has remitted reassessment cases for fresh consideration after the retrospective insertion of Section 147A, leavi...
Income Tax : Learn the most frequent errors taxpayers make while filing Income Tax Returns for AY 2026-27 and how avoiding them can prevent not...
Income Tax : The article explains how the interaction of Section 87A, marginal relief, and Health & Education Cess can leave taxpayers earning ...
Income Tax : Learn who can apply for an advance ruling, applicable fees, withdrawal rules, and its binding effect under the Income-tax Act. The...
Income Tax : Net direct tax collections for FY 2026-27 grew by 14.64% as of June 17, 2026, driven by higher corporate and non-corporate tax rec...
Income Tax : The CBI apprehended an Income Tax Office Superintendent in Odisha after he was allegedly caught accepting a bribe for deleting a d...
Income Tax : The Income Tax Appellate Tribunal has proposed a priority disposal mechanism for appeals filed up to and including 2022 in respons...
Income Tax : A representation has urged CBDT to merge TDS return codes 1023 and 1024, arguing that both apply to the same contract payments wit...
Income Tax : Association requested CBDT to rationalize CASS 2026 case selection considering the administrative burden caused by implementation ...
Income Tax : The High Court held that failure to pass the order giving effect within the time prescribed under Section 153 resulted in abatemen...
Income Tax : The Madras High Court held that unexplained trade credits falling under Section 68 cannot qualify for deduction under Section 80-I...
Income Tax : The Tribunal restricted the Section 14A disallowance to exempt income and deleted additions relating to bad debts, tea and coffee ...
Income Tax : The ITAT held that the CPC could not make adjustments under Section 143(1) without first issuing the mandatory intimation to the a...
Income Tax : The ITAT Mumbai held that Fees for Technical Services were taxable at 10% under section 115A(1)(b) since the RBI's automatic appro...
Income Tax : CBDT has approved a scientific research institution under the Income-tax Act, 2025 for tax years 2026-27 to 2030-31. The notificat...
Income Tax : CBDT has approved the University of Hyderabad for scientific research under Section 45 of the Income-tax Act, 2025. The approval i...
Income Tax : The CBDT has identified specific categories of taxpayers whose returns will be compulsorily selected for complete scrutiny during ...
Income Tax : The Ordinance exempts interest income and capital gains arising from Government securities for Foreign Institutional Investors and...
Income Tax : The Central Government has specified infrastructure sub-sectors from the Updated Harmonised Master List as eligible businesses und...
In this case there is nothing in the reasons to indicate that there is an escapement of income, but, at the most, need to verify that the reasons of discrepancy between income from profession as per return of income vis-à-vis as per the certificates of tax deduction at source. A variation in these two figures does not necessarily lead to escapement of income,
Whether the penalty was imposed U/s 271(1)(c ) because of the reason that the deduction claimed under section 80-IB by the respondent-assessee was ultimately allowed at a lower level were valid?
The assessment record reveals that the MLA had been placed on the record of the Assessing Officer in the very first instance when the assessment was completed under section 143(3). Thereafter the reassessment proceedings were initiated for those proceedings too and what drove the revenue to issue notice and reopen the proceedings was the master licensing agreement and the nature of ‘royalty income’. The Assessing Officer in that instance consciously after going through the material concluded that the rate of taxation was 15 per cent in the reassessment proceedings.
Learned counsel for the appellant submitted that in the facts and circumstances of the case no penalty was leviable as the appellant itself had surrendered the said amount representing the difference in the sundry creditors in order to buy peace. He, thus, submitted that there was no concealment of income so as to warrant levy of penalty under Section 271(1)(c) of the Act.
As regards investment made in thandal business, there are no materials seized at the time of search of the assessee’s premises, to make this as a subject matter of block assessment. When the revenue does not dispute the fact that the assessee had been doing the business along with two others, there was no justifiable ground to assess Rs. 27 lakhs at the hands of the assessee.
On going through the records, we find that the issues that were raised were not discussed and dealt with by the High Court except for saying that the case is not a fit case to be interfered with. According to us, this is not a proper disposal of the appeal. Accordingly, we set aside the order and remit back the matter for fresh disposal de novo in accordance with law.
The TPO has to work out the ALP of the international transaction by applying the methods recognized under the Act. He is not competent to hold that the expenditure in question has not been incurred by the assessee or that the assessee has not derived any benefits for the payment made by the assessee and consequently, he cannot consider the ALP as NIL.
U/s 9(1)(vi)(c) royalty payable by a person who is a non-resident is deemed to arise in India where the royalty is payable in respect of any right etc utilised for the purposes of a business carried on by such person in India or for the purposes of earning any income from any source in India. Section 9(1)(vi)(c) is a deeming provision and the burden is on the Revenue to prove that the payer has a business/ source of income in India. What is important for Section 9(1)(vi)(c) is not whether the right to property is used “in” or “for the purpose of” a business, but to determine whether such business is “carried on by such person in India”;
During the assessment year 2006-07 in question in the provisions laid down u/s 32(i)(iia) there was specific condition alongwith installation of new plant or machinery after 31st March, 2005 that the new plant or machinery must also be acquired after 31st March, 2005.
After the search and the statement recorded under section 132(4), the assessee, on being issued with notice under section 153A did not file any return. The notice under section 153A was issued on 20-7-2006. It was only when assessment proceedings were taken up for consideration, did the assessee, by letter dated 14-8-2007, request that its return, filed on 31-10-2005,
