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Income Tax : Section 50AA overrides the normal holding period rules and deems gains from specified assets as short-term capital gains, even if ...
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 : 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 Tribunal ruled that proceedings initiated under the old Section 153C framework after the Finance Act, 2021 amendments were leg...
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 : 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...
If we consider the facts of the case under consideration, we noticed that the A.O. did not reject the books of account regularly maintained by the assessee by invoking section 145(3) of the Act. The assessee raised the ground before the CIT(A) that reference under section 142A to the D.V.O. is without jurisdiction as the A.O. did not reject the books of account.
The investment with the sister-concerns had no nexus to the assessee’s business activities. They were merely invested for the purpose of earning interest. The assessee has not even established that one of its business activities was to advance loans to third parties and/or to invest its funds and that it was a mere coincidence that over the years, all the advances were made to and the investments were made in their sister-concerns.
Objects of the appellant even after the amendment of the trust deed continue to be charitable. The amendment is a mere power conferred on the Trust or other institution. It has to be shown on facts that any amendment to the objects clause has resulted in the trust or institution becoming non charitable in character.
Whether the Appellate Tribunal is right in law in holding that unrealised export turnover should be included in the Total Turnover while it is not treated as Export Turnover for purposes of computing the allowable deduction under Section 80HHC ?
Tribunal has considered the entire evidence and on facts come to the conclusion that the profits earned by Kandla division of the respondent-assessee is not abnormally high due to any arrangement between the respondent-assessee and its German Principal. The Tribunal correctly held that extraordinary profits cannot lead to the conclusion that this is an arrangement between the parties.
After going through the order of CIT(A), We find that CIT(A) has passed a non-speaking order by following the decision of ITAT in the case of Multiplan India (Pvt.) Ltd. (supra). We are of the view that where appeal has been disposed of even though on merits without a speaking order, the order of CIT(A) cannot be sustained.
The language used in section 10(23C)(iiiad)speaks about existence of solely for educational purposes and not for the purposes of profit if the annual receipts do not exceed the prescribed limit. However, if the aforesaid chart/income is analysed, we find that a huge abnormal profit has been created/earned by the assessee and the amounts are definitely beyond the prescribed limit.
However, in the case of a non-competition agreement or covenant, the advantage is a restricted one, in point of time. It does not necessarily – and not in the facts of this case, confer any exclusive right to carry-on the primary business activity.
In the present case, both, the Commissioner (Appeals) as well as the Tribunal have found that the transactions in question are neither in the nature of loans or deposits. Under the circumstances, the provisions of sections 269SS and 269T of the Act would not be applicable. Consequently, the question of contravention of such provisions attracting penalty under sections 271D and 271E of the Act would also not arise. Under the circumstances, no infirmity can be found in the impugned order of the Tribunal so as to give rise to a question of law, much less, a substantial question of law so as to warrant interference.
Mere possession of money, bullion, jewelery or such valuable article or thing per-se would not be sufficient to enable the competent officer to form a belief that the same had not been or would not be disclosed for the purpose of the Act. What is required is some concrete material to enable a reasonable person to form such a belief.
