Income Tax : Faceless Income-tax proceedings and e-assessments under Section 144B simplify taxpayer compliance. Use the e-filing portal for ele...
Income Tax : Understand Sections 234A, 234B, 234C, and 234D of the Income Tax Act covering interest on late filing, short payment, delayed adva...
Income Tax : A summary of key penalties under the Income Tax Act for AY 2026-27, covering defaults from late filing and non-payment to misrepor...
Income Tax : Understand how interest under the Income Tax Act is calculated, including Sections 234A–234D, 244A, and Rule 119A mechanics for ...
Income Tax : A look into why taxpayers face interest charges under Sections 234B and 234C, exploring how Section 210, a provision for official ...
Income Tax : Request to CBDT to permit filing of Form 10IC after expiration of time limit by condoning delay Issuance of Order under Section ...
Income Tax : All Odisha Tax Advocates Association has filed an PIl before Orissa High Court with following Prayers- (i) Admit the Writ Petition...
Income Tax : Recommendation For Amendment To Section 234C To Provide Relief Where A New Business Is Started During The Financial Year Section 2...
Income Tax : The issue involved taxing capital gains from a development agreement in multiple years. The court held the same income cannot be t...
Income Tax : Reassessment quashed by ITAT Bangalore as failure to pass a speaking order on objections violated mandatory procedure under Sectio...
Income Tax : The Tribunal held that reopening under Section 147 was invalid where it was based on third-party search material. It ruled that Se...
Income Tax : The Tribunal held that purchases cannot be treated as bogus when supported by invoices, bank payments, and GST records. It ruled t...
Income Tax : The issue was incorrect computation of interest without reducing foreign tax relief. ITAT held that relief under sections 90/90A m...
The Tribunal held that an enforceable agreement to sell, supported by advance consideration, constitutes transfer under Section 2(47), entitling the assessee to Section 54 relief.
The Tribunal held that a continuously maintained ledger found during search constituted reliable evidence. Additions for unexplained expenditure under section 69C were sustained based on corroborated diary entries.
ITAT Mumbai held that where segmental accounts are not available, then proportionate adjustments have to be made only in respect of the international transactions with associated enterprises [AE]. Thus, TPO directed to compute the transfer pricing [TP] adjustment, restricting it to the international transactions undertaken with associated enterprises.
The case examined whether disallowance under section 14A could be made when no expenditure relating to exempt income was claimed. The Tribunal held that unclaimed expenses cannot be disallowed. The ruling reinforces that section 14A applies only to deductions actually claimed.
ITAT Mumbai held that long-term capital gains earned from the transactions, which are grandfathered as per the provisions of Article 13(4) of the India-Mauritius DTAA, doesn’t form part of total income hence cannot be adjusted against the brought forward long-term capital loss incurred by the assessee. Accordingly, order set aside.
The tribunal held that reassessment under Section 153C cannot stand without valid satisfaction as mandated by law. Failure to examine this jurisdictional issue vitiates the proceedings.
The Tribunal emphasized that exempt income disclosed in the return cannot be taxed due to a technical reporting mistake. Substance of disclosure prevails over form where facts are undisputed.
Purchase Date Doubts Not Enough to Deny LTCG Exemption: ITAT Mumbai held that transfer dates shown in share certificates satisfied the statutory holding requirement.
The Revenue argued AMP functions required separate compensation under DEMPE principles. The Tribunal rejected this, holding that consistent past rulings prevail absent material factual change.
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.
