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Income Tax : Budget 2026 has extended the due dates for ITR-3, ITR-4, and revised returns, offering taxpayers greater flexibility. Understandin...
Income Tax : Relocating to Sikkim does not automatically exempt you from income tax. This article explains who qualifies under Section 10(26AAA...
Income Tax : The article outlines practical methods through which business owners and professionals can legally minimise their tax burden. It h...
Income Tax : Section 54 grants exemption on long-term capital gains from the sale of a residential house because the proceeds are reinvested in...
Income Tax : The Income-tax Act mandates e-payment of direct taxes for companies and taxpayers covered under Section 44AB, while others may opt...
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 : KSCAA requested the CBDT to release e-filing utilities and schemas for AY 2026-27 without delay, stating that pending utilities ar...
Income Tax : The ITAT Chennai held that an Assessing Officer cannot introduce a new addition while giving effect to an appellate order. Since t...
Income Tax : The Tribunal held that actual rent received under genuine, registered agreements cannot be replaced with hypothetical market rent ...
Income Tax : ITAT found that the assessee had sufficient cash resources to meet the impugned credit card payments. Since the authorities did no...
Income Tax : The Calcutta High Court held that refund adjustment against a disputed tax demand was unsustainable when both a stay application a...
Income Tax : The High Court questioned the Revenue's refusal to grant credit for advance tax and TDS despite substantial amounts already lying ...
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...
Income Tax : CBDT has granted scientific research approval under the Income-tax Act, 2025, enabling eligible donations to qualify for tax benef...
Income Tax : CBDT has granted scientific research approval under the Income-tax Act, 2025, allowing eligible donations to qualify for tax benef...
The ITAT Delhi ruled that Marketing & Reservation Contributions (MRC) received by a US-based hotel brand entity from Indian franchisees are not taxable as Fees for Technical Services (FTS) or Royalty under the India-US DTAA. The Tribunal followed the principle of judicial consistency, reiterating that these receipts were not compensation for managerial or technical services.
ITAT Delhi dismissed Revenue’s appeal, deleting a ₹2.18 crore Transfer Pricing (TP) adjustment on palm oil imports. Tribunal ruled that taxpayer rightly used Comparable Uncontrolled Price (CUP) method based on Kuala Lumpur Commodity Exchange (KLCE)-derived broker quotes, confirming CUP as the most appropriate method for commodity trading.
Assessment order was quashed because ITO who issued the Section 143(2) notice exceeded their pecuniary limits as prescribed by CBDT instructions. This decision provides a key takeaway that the jurisdiction limit set by the CBDT for assigning cases to ITOs versus higher-ranking officers is mandatory, and a breach invalidates the assessment proceedings.
The Delhi ITAT sustained a Rs.42.98 lakh addition for unexplained expenditure found in a seized diary, ruling that the entries proved a sufficient nexus to the assessee under Section 292C. However, the Tribunal provided partial relief by directing the lower tax rate under the pre-amendment Section 115BBE to be applied for AY 2015-16.
The ITAT confirmed the reopening u/s 147/148 beyond the four-year limit was valid, as information from the wife’s assessment about the joint account constituted a new and tangible reason to believe income escaped. Despite upholding the reopening, the Tribunal granted significant taxpayer relief by accepting documentary evidence for property-related transactions and reducing the addition to a minimal amount.
The Tribunal directed the CIT(E) to grant Section 12A registration, holding that the Commissioner exceeded jurisdiction by focusing on commercial aspects like fee levels and profitability at the registration stage. The ruling confirms that only the genuineness of the objects and activities must be examined when processing a charitable trust’s application.
Citing lack of sufficient cause for condonation, the Tribunal ruled that even charitable entities cannot escape limitation rules, dismissing the appeal filed after over six years.*
The Karnataka High Court set aside a penalty notice and order under Section 271DA for violating Section 269ST, holding the proceedings were time-barred. Following the K. Umesh Shetty precedent, the Court ruled that the delay between the AO’s reference and the penalty notice constituted unreasonable laches, vitiating the entire action.
Upholding the sanctity of concluded proceedings, the Court rejected the Revenue’s challenge, holding that the Checkmate Services judgment on PF/ESI contributions cannot retroactively invalidate a prior ITAT order. The key takeaway is that the ITAT’s power under Section 254(2) is limited, and a later change in law is not a ground to disturb a settled matter.
The Karnataka High Court dismissed the Revenue’s petition, affirming that the ITAT correctly refused to rectify its concluded order using the later Supreme Court ruling in Checkmate Services. The ruling emphasizes that Section 254(2) is only for mistakes apparent from the record, and a subsequent change in law cannot reopen a finalized judicial adjudication.