ITAT deleted addition due to invalidity of proceedings under Sections 147/148 and improper transfer under Section 127
ITAT deleted addition due to invalidity of proceedings under Sections 147/148 and improper transfer under Section 127 Hon’ble ITAT, Indore in the case of M/s. Shakshi Township Pvt. Ltd. (AY 2011-12) has quashed the reassessment order solely on jurisdictional grounds, highlighting the invalidity of proceedings under Sections 147/148 and improper transfer under Section 127…. […]
TDS not applicable on commission to NRI agents procuring foreign customers
TDS not applicable on commission to NRI agents procuring foreign customers In a recent case, AO made disallowance u/s 40(a)(i) for not deducting TDS on commission paid to non-resident agent for procuring foreign customers. CIT(A) also upheld the disallowance. On further appeal, the Hon’ble ITAT appreciated our submissions that the NRI agent has no… […]
AO neither rejected the books nor conducted verification under Section 133(6): ITAT deleted addition under Section 68
AO neither rejected the books nor conducted verification under Section 133(6): ITAT deleted addition under Section 68 Demonetisation Cash Deposits Fully Explained – ITAT Hyderabad Deletes ₹96.26 Lakh Addition Under Section 68, Accepts Books & Debtor Confirmations as Genuine The ITAT Hyderabad deleted an addition of ₹96.26 lakh made under Section 68 for cash deposits during… […]
Both JAO and FAO have concurrent jurisdiction to initiate reassessment proceedings under section 148
Both JAO and FAO have concurrent jurisdiction to initiate reassessment proceedings under section 148 The petitioners filed an instant writ petition and contended that the Faceless Assessing Officer (FAO) would have the jurisdiction to initiate reassessment proceedings under section 148.The petitioners submitted that multiple judicial pronouncements stated that it was the FAO, that should… […]
Condonation of Delay under Section 119(2)(b) – CBDT Circular Cannot Override Substantive Right to Refund: HC
Condonation of Delay under Section 119(2)(b) – CBDT Circular Cannot Override Substantive Right to Refund: HC Santhana Krishnan (WP No. 21071 of 2025) Facts: 1. Petitioner is a Non-Resident Indian (resident of United States) who sold immovable property in FY 2022–23 and deducted & remitted tax, but failed to file return u/s 139. 2. … […]
Taxation of Joint Development Agreements (JDAs) in the Context of the New Income Tax Act, 2025:
Taxation of Joint Development Agreements (JDAs) in the Context of the New Income Tax Act, 2025: Introduction: This note outlines the current and prospective tax framework for Joint Development Agreements (JDAs), confirming the continuity of established provisions following the enactment of the new Income Tax Act, 2025. The core mechanism for taxing capital gains… […]
Madras High Court Quashes Reassessment as Time-Barred and Without Jurisdiction:
Madras High Court Quashes Reassessment as Time-Barred and Without Jurisdiction: Tamilselvi v. ITO Facts: 1. Notices under Sections 148A(b) and 148 were issued in the transitional phase after the 2021 amendment to the reassessment provisions. 2. The petitioner challenged the validity of these notices and consequential orders as: Time-barred in light of the Supreme… […]
How Nagpur’s Tax Drive Signals a Nationwide Shift in Transparency
How Nagpur’s Tax Drive Signals a Nationwide Shift in Transparency Ever watched one of those crime thrillers where the thief thinks he’s committed the perfect heist-no witnesses, no fingerprints, no CCTV footage-only for the detective to walk in, smile, and say, “You forgot one thing”? Welcome to Nagpur, where that detective isn’t a movie… […]
Understanding Tax Exemption and TDS Issues on Land Acquisition Compensation
Understanding Tax Exemption and TDS Issues on Land Acquisition Compensation Introduction: 1. The acquisition of land by Government authorities or other agencies often raises questions regarding the taxability of compensation received by landowners. 2. This note outlines the current legal position on taxation and TDS applicability on land acquisition compensation. Legal framework: 1. Under… […]
Regulatory Exposure of High-Net-Worth Families under the Black Money Law:
Regulatory Exposure of High-Net-Worth Families under the Black Money Law: Introduction: Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015 (“BMA”) was enacted to target undisclosed foreign income and assets of Indian residents. The Act imposes: Tax @ 30% on the value of undisclosed foreign income and assets, and Penalty… […]
