Post-Supply Discount Adjustments and ITC Mismatches Remanded for Detailed Investigation and Verification of Tax Records

By | November 4, 2026
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Post-Supply Discount Adjustments and ITC Mismatches Remanded for Detailed Investigation and Verification of Tax Records Issue Valuation & Post-Supply Discounts: Whether post-supply discounts/incentives received from an OEM (Honda) and disclosed in GSTR-9C warrant output tax demands or Input Tax Credit (ITC) adjustments without verifying whether the supplier issued credit notes and reduced taxable values. Double… Read More »

INCOME TAX CASE LAWS 03.11.2026

By | November 4, 2026
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INCOME TAX CASE LAWS 03.11.2026   Here is the structured analysis of the provided case laws, presented in tabular format: Section Case Law Title Brief Summary Citation Relevant Act N/A Income-tax Gazetted Officers Association (ITGOA) v. Union of India Dismissal of SLP against High Court order holding that Private Secretaries seeking pay parity with Central… Read More »

Cross-Objections Are Maintainable in Appeals Under Section 260A Subject to Satisfying Substantial Questions of Law

By | November 4, 2026
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Cross-Objections Are Maintainable in Appeals Under Section 260A Subject to Satisfying Substantial Questions of Law Issue Whether a respondent in an appeal filed under Section 260A of the Income-tax Act, 1961 is legally entitled to maintain a cross-objection proposing additional substantial questions of law under Order XLI Rule 22 read with Order XLII of the… Read More »

Reassessment Notice Issued Under Amended Section 149 After Expiration of Old Six-Year Limitation Period Is Time-Barred and Void

By | November 4, 2026
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Reassessment Notice Issued Under Amended Section 149 After Expiration of Old Six-Year Limitation Period Is Time-Barred and Void Issue Whether a reassessment notice issued under Section 148 on 27-07-2022 for Assessment Year 2013-14 is barred by limitation, considering the interplay between the old and amended provisions of Section 149 regarding the extended ten-year limitation period.… Read More »

Reassessment Based on Existing Records Without Fresh Tangible Material Amounts to Impermissible Change of Opinion

By | November 4, 2026
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Reassessment Based on Existing Records Without Fresh Tangible Material Amounts to Impermissible Change of Opinion Issue Whether reopening an assessment under Section 147/148 beyond four years based solely on existing assessment records—without fresh tangible material or a finding of failure to disclose fully and truly all material facts—constitutes an impermissible change of opinion, rendering the… Read More »

Best Judgment Assessment Passed Without Hearing or Responding to Adjournment Request Set Aside

By | November 4, 2026
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Best Judgment Assessment Passed Without Hearing or Responding to Adjournment Request Set Aside Issue Whether a best judgment assessment order passed under Section 144 read with Section 144B of the Income-tax Act, 1961 is legally sustainable when the Assessing Officer (AO) provided an inadequate reply window, failed to respond to an adjournment request, and issued… Read More »

Interest Earned by Cooperative Society on Deposits with Cooperative Bank Qualifies for Deduction Under Section 80P(2)(d)

By | November 4, 2026
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Interest Earned by Cooperative Society on Deposits with Cooperative Bank Qualifies for Deduction Under Section 80P(2)(d) Issue Whether a cooperative society engaged in the procurement and distribution of milk is entitled to claim deduction under Section 80P(2)(d) of the Income-tax Act, 1961 in respect of interest income derived from investments/deposits held with a cooperative bank.… Read More »

Section 148 Notice Based on Uncorroborated Third-Party Seized Registers Without Live Nexus to Assessee Quashed

By | November 4, 2026
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Section 148 Notice Based on Uncorroborated Third-Party Seized Registers Without Live Nexus to Assessee Quashed Issue Whether a notice issued under Section 148 alleging payment of “on-money” for land purchase is legally sustainable when based solely on third-party inquiry registers seized during a search on a real estate broker, where neither the broker’s sworn statement… Read More »

Reporting Errors in Schedule AL Cannot Automatically Trigger Section 69 Unexplained Investment Additions

By | November 4, 2026
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Reporting Errors in Schedule AL Cannot Automatically Trigger Section 69 Unexplained Investment Additions Issue Whether a clerical or inadvertent disclosure error in Schedule AL of the Return of Income regarding closing investment figures can automatically justify an addition under Section 69 read with Section 115BBE without the Assessing Officer leading positive evidence of actual fresh… Read More »

Individual Below Turnover Limit Exempt from TDS under 194A and Interest Expenditure Allowed under Section 57(iii)

By | November 4, 2026
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Individual Below Turnover Limit Exempt from TDS under 194A and Interest Expenditure Allowed under Section 57(iii) Issue Scope of TDS under Section 194A: Whether an individual assessee whose business turnover in the preceding year did not exceed the prescribed monetary limits under the proviso to Section 194A(1) is required to deduct tax at source (TDS)… Read More »