Has the Supreme Court Quietly Diluted the “Change of Opinion” Doctrine? A Critical Look at Sanand Properties Pvt. Ltd. vs. JCIT
Has the Supreme Court Quietly Diluted the “Change of Opinion” Doctrine? A Critical Look at Sanand Properties Pvt. Ltd. vs. JCIT The Supreme Court’s recent ruling in Sanand Properties Pvt. Ltd. vs. JCIT [(2026 INSC 472) dated 12.05.2026], authored by Hon’ble Justice J.B. Pardiwala, may prove to be one of the most consequential reassessment judgments delivered… […]
Penalty Under Section 270A Invalid if AO Fails to Specify Exact Charge: Important ITAT Bangalore Ruling
Penalty Under Section 270A Invalid if AO Fails to Specify Exact Charge: Important ITAT Bangalore Ruling In a significant ruling on penalty proceedings under Section 270A of the Income Tax Act, the Bangalore Bench of the Income Tax Appellate Tribunal (ITAT Bangalore) has held that penalty proceedings become legally unsustainable where the Assessing Officer… […]
ITAT Mumbai: Business Expenditure Cannot Be Disallowed Merely on Suspicion, Assumptions, or Surmises
ITAT Mumbai: Business Expenditure Cannot Be Disallowed Merely on Suspicion, Assumptions, or Surmises In a significant ruling reinforcing the principles of consistency and evidence-based taxation, the Mumbai Bench of the Income Tax Appellate Tribunal (ITAT Mumbai) has held that business expenditure cannot be disallowed merely on doubts, assumptions, or surmises when: • Supporting… […]
ITAT Chandigarh Grants Major Relief Under Section 54: Old Construction Cost Cannot Be Rejected Merely for Lack of Old Bills
ITAT Chandigarh Grants Major Relief Under Section 54: Old Construction Cost Cannot Be Rejected Merely for Lack of Old Bills In a significant ruling on capital gains exemption under Section 54 of the Income Tax Act, the Chandigarh Bench of the Income Tax Appellate Tribunal (ITAT Chandigarh) has held that indexed cost of… […]
Substance Over Form: ITAT Mumbai Reaffirms Appellate Powers to Entertain New Claims Without Revised Return
Substance Over Form: ITAT Mumbai Reaffirms Appellate Powers to Entertain New Claims Without Revised Return In a significant ruling reinforcing the principle that taxation must ultimately reflect the correct legal liability and not procedural rigidity, the Mumbai Bench of the Income Tax Appellate Tribunal (ITAT Mumbai) has held that appellate authorities can entertain… […]
NRI Selling Property in India? Beware: TDS Rules Have Changed Under the New Income Tax Act, 2025
NRI Selling Property in India? Beware: TDS Rules Have Changed Under the New Income Tax Act, 2025 The sale of immovable property by Non-Resident Indians (NRIs) has always been a compliance-sensitive area. While most taxpayers are familiar with the old Section 195 of the Income-tax Act, 1961, the introduction of the Income-tax Act, 2025… […]
ITAT Indore Drops Penalty Under Section 271AAC: “When Quantum Fails, Penalty Cannot Survive”
ITAT Indore Drops Penalty Under Section 271AAC: “When Quantum Fails, Penalty Cannot Survive” In an important reaffirmation of a settled principle of tax jurisprudence, the Indore Bench of the Income Tax Appellate Tribunal (ITAT Indore) has held that penalty proceedings under Section 271AAC cannot survive independently once the underlying quantum assessment itself has… […]
How AI Is Quietly Changing Income Tax Assessments
How AI Is Quietly Changing Income Tax Assessments There was a time when income tax scrutiny depended largely upon manual selection, human suspicion and occasional luck. Taxpayers often believed that unless their file landed on the “wrong officer’s table”, the chances of detailed scrutiny were relatively low. That era is disappearing rapidly. Today,… […]
AO Cannot Travel Beyond Limited Scrutiny Scope Without Approval: Tribunal Quashes Addition
AO Cannot Travel Beyond Limited Scrutiny Scope Without Approval: Tribunal Quashes Addition In an important ruling protecting taxpayers against jurisdictional overreach in limited scrutiny cases, the Tribunal has held that an Assessing Officer cannot examine issues beyond the specific reason for which the case was selected under CASS unless prior approval for conversion… […]
Section 153C Proceedings Invalid if Satisfaction Note Recorded After 01.04.2021: Important Tribunal Ruling
Section 153C Proceedings Invalid if Satisfaction Note Recorded After 01.04.2021: Important Tribunal Ruling In a significant ruling impacting search-related assessments involving third parties, the Tribunal has held that proceedings under Section 153C of the Income Tax Act are not maintainable where the satisfaction note was recorded after 01.04.2021. The Tribunal, in Shaminder Singh vs. ACIT, quashed… […]
