Income Tax : Budget 2026 proposes allowing taxpayers to file an updated return even after receiving a reassessment notice under Section 148. Wh...
Income Tax : Misreporting under Section 270A(9) applies only to six specific circumstances. Where the assessment order does not clearly establi...
Income Tax : The law now proposes a single consolidated assessment-cum-penalty order for under-reporting of income, reducing multiple proceedin...
Income Tax : Detailed overview of penalties under various sections of the Income Tax Act, covering defaults in tax payment, reporting, document...
Income Tax : Section 270A penalties must specify the exact misreporting clause. Vague notices invalidate penalties and can restore immunity und...
Income Tax : Explore amendments to section 253 of Income-tax Act, adjusting time limits for filing appeals to the Income Tax Appellate Tribunal...
Income Tax : The tribunal examined whether duty drawback should be taxed on accrual or actual receipt. It held that as per law, duty drawback i...
Income Tax : ITAT held that interest earned on bank deposits is taxable and not covered by the principle of mutuality. The ruling confirms that...
Income Tax : The Tribunal restored the penalty matter as the quantum addition was sent back to the AO. It held that penalty must follow the out...
Income Tax : The issue was penalty for misreporting on sale of land classified as capital asset. The Tribunal held the issue was debatable and ...
Income Tax : The case examined whether disallowance under section 94(7) should be limited to exempt dividend. The Tribunal held that the provis...
ITAT Delhi applied the principle that if the foundation (quantum addition) is removed, the superstructure (penalty) collapses. The Section 270A penalty was deleted once the quantum was wiped out. Takeaway: penalties require surviving taxable additions.
The Tribunal held that a captive software development service provider cannot be compared with giant IT companies owning IP, diversified services, and global operations. By excluding these functionally dissimilar comparables, the entire ₹10.58 crore TP adjustment was deleted.
ITAT emphasized that taxpayers must substantiate the receipt and benefit of group services, remanding the matter due to inadequate examination by lower authorities.
The Tribunal applied long-standing rulings invalidating the intensity and BLT approaches for AMP benchmarking, deleting both substantive and protective adjustments. The decision underscores that such methods lack statutory support.
ITAT restored penalties under Sections 271AAC and 270A after noting CIT(A) dismissed appeal without hearing assessee. Case highlights necessity of providing a fair opportunity before imposing penalties.
ITAT Kolkata held that an addition cannot be sustained solely on a survey statement under Section 133A. Proper verification of stock and business records is required before treating income as undisclosed.
ITAT Mumbai ruled that once the Assessing Officer is aware of a merger, assessment in the name of the amalgamating company is invalid and without jurisdiction.
Delhi High Court held that tax authorities cannot replace projected business valuations with actual results when assessing transfer pricing, emphasizing commercial prudence principle in asset transfers.
ITAT Jaipur held that addition towards unsecured loan cannot be sustained since identity of lenders, creditworthiness of parties and genuineness of loan transaction duly proved. Accordingly, CIT(A) order upheld and appeal of revenue dismissed.
Tribunal held that tax authorities erred in invoking Article 24A to deny capital gains exemption under Article 13(4A) without first satisfying preconditions of economic substance. The decision underscores that anti-abuse provisions cannot override bona fide investments made before 2017.
