Income Tax : The article explains remedies available after adverse tax orders under scrutiny and reassessment. The key takeaway is that choosin...
Income Tax : The Court clarified that mere pendency of information exchange requests under DTAA cannot justify continuing a Look Out Circular. ...
Income Tax : A surge in Section 143(2) notices was triggered by the June 2025 limitation deadline. This explains why cases were picked and how ...
Income Tax : The Tribunal ruled that penalty under Section 271A cannot be levied merely because books were rejected and income was estimated. S...
Income Tax : The ITAT held that an assessment completed before receiving the DVO report under section 50C(2) is invalid. All additions and disa...
Income Tax : Delhi ITAT allows Sanco Holding, a Norwegian company, to compute income from bareboat charter of seismic vessels under Article 21(...
Income Tax : It has been observed that in many cases an assessee may wish to make a claim which was not made in the return of income filed unde...
Income Tax : We have attached a file in excel format. The file contains the format of various details which normally assessing officer asks As...
Income Tax : Tribunal observed that the Assessing Officer failed to establish any mismatch in stock, sales, or accounting records before making...
Income Tax : ITAT Hyderabad held that constituent members of a JV or Consortium can claim deduction under Section 80IA(4) when they actually ex...
Income Tax : The Tribunal found that full payment, TDS deduction, and transfer of possession established completion of the transaction for capi...
Income Tax : ITAT Rajkot held that cash deposits made during demonetization were fully supported by audited books of account, cash books, and b...
Income Tax : The Hyderabad ITAT held that purchases cannot be treated as bogus merely because the supplier failed to respond to a notice under ...
Income Tax : Instruction No.1/2015 Clarification regarding applicability of section 143(1D) of the Income-tax Act, 1961- Vide Finance Act, 2012...
The issue concerned treating business creditors as unexplained cash credits due to non-response to notices. The Tribunal held that corroborative balance sheets and ledger evidence warranted fresh verification, and remanded the matter to the AO.
The Tribunal ruled that penalty proceedings are consequential to assessment. When the assessment issue is pending before the High Court, penalty cannot be enforced.
The Tribunal examined whether revision under section 263 could survive when the show-cause notice was issued to an entity that had already ceased to exist due to amalgamation. It held that proceedings against a non-existent entity are void ab initio, rendering the revision order invalid.
The Tribunal reaffirmed that reassessment cannot be based on re-appreciation of facts already scrutinized earlier. Without failure of disclosure, invoking Section 147 beyond four years was invalid.
The Tribunal ruled that repeated reopening cannot survive where statutory timelines are breached. A reassessment initiated beyond the permissible surviving period was quashed in entirety.
The Tribunal examined whether a branch office treated as a permanent establishment can deduct head-office cost reimbursements. ITAT held that full cost deduction is mandatory so that only profits attributable to the PE are taxed under Article 7.
The Tribunal held that no interest disallowance can be made when ample interest-free funds are available. The key takeaway is that diversion cannot be presumed without establishing a nexus with borrowed funds.
The Tribunal considered whether disallowance under section 14A was justified merely because exempt income was earned. It ruled that without corresponding investments in the assessee’s books, section 14A cannot be invoked.
The ITAT held that reassessment proceedings remain valid even if no separate addition is made on the original reopening issue. The key lesson is that voluntary disclosure by the assessee satisfies the reopening requirement.
The Tribunal held that only unreconciled Form 26AS entries could be taxed while verified reimbursements deserved relief. It also ruled that godown rent already netted in business income could not be taxed again.
