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    July 15, 2026   Case Laws Income Tax
    Section 80-IA eligibility, change of opinion, and audit-driven reopening lead to invalid reassessment proceedings
    July 15, 2026   Case Laws Income Tax
    Electronic dispatch determines reassessment notice issuance, requiring Section 148A safeguards when delivery occurs after the statutory transition.
    July 15, 2026   Case Laws Income Tax
    Section 263 revision requires demonstrated error and Revenue prejudice; completed inquiry cannot be reopened merely for deeper verification
    July 15, 2026   Case Laws Income Tax
    Jurisdictional satisfaction and limitation govern cash-acceptance penalties; proceedings under section 271D fail when either requirement is absent.
    July 15, 2026   Case Laws Income Tax
    Avoiding double taxation of reversed bonus provisions, while allowing standard-asset provisions and employee incentives under applicable principles
    July 15, 2026   Case Laws Income Tax
    Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
    July 15, 2026   Case Laws Income Tax
    Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
    July 15, 2026   Case Laws Income Tax
    Bona fide computational errors with full disclosure may exclude section 270A penalty, even where returned loss is reduced.
    July 15, 2026   Case Laws Income Tax
    Unascertainable TDR acquisition cost defeats capital gains computation; later deeming rules cannot retrospectively create chargeability
    July 15, 2026   Case Laws Income Tax
    Legal impossibility limits section 234A interest, while reverse indexation may support verified cost estimation for old property capital gains
    July 15, 2026   Case Laws Income Tax
    Separate maintenance agreements support business-income treatment, while replacement-loan interest may remain deductible for let-out property.
    July 15, 2026   Case Laws Income Tax
    Buying agency services remain business income, not technical fees, where procurement support lacks managerial, technical or consultancy character
    July 15, 2026   Case Laws Income Tax
    Registered property transfer fixes capital-gains tax year; absolute ownership governs assessment, with later-year tax credited appropriately
    July 15, 2026   Case Laws Income Tax
    Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
    July 15, 2026   Case Laws Income Tax
    Slump sale prevents repeat capital-gains taxation when later conveyance registration merely perfects title to transferred undertaking assets
    July 15, 2026   Case Laws Income Tax
    Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
    July 15, 2026   Case Laws Benami Property
    Fictitious-name benami transactions may justify attachment in the beneficial owner's account when cumulative evidence disproves genuine supply
    July 15, 2026   Case Laws Customs
    Sufficient cause limits late filing fees where supplementary cargo declarations reflect genuine bulk measurement and moisture variations
    July 15, 2026   Case Laws Customs
    Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
    July 15, 2026   Case Laws Customs
    Duty-free EOU input destruction under intimation attracts no duty; clarificatory amendments apply retrospectively and penalties fail absent suppressio...
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July 15, 2026   Case Laws Income Tax
Section 80-IA eligibility, change of opinion, and audit-driven reopening lead to invalid reassessment proceedings
July 15, 2026   Case Laws Income Tax
Electronic dispatch determines reassessment notice issuance, requiring Section 148A safeguards when delivery occurs after the statutory transition.
July 15, 2026   Case Laws Income Tax
Section 263 revision requires demonstrated error and Revenue prejudice; completed inquiry cannot be reopened merely for deeper verification
July 15, 2026   Case Laws Income Tax
Jurisdictional satisfaction and limitation govern cash-acceptance penalties; proceedings under section 271D fail when either requirement is absent.
July 15, 2026   Case Laws Income Tax
Avoiding double taxation of reversed bonus provisions, while allowing standard-asset provisions and employee incentives under applicable principles
July 15, 2026   Case Laws Income Tax
Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus alone.
July 15, 2026   Case Laws Income Tax
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scrutiny
July 15, 2026   Case Laws Income Tax
Bona fide computational errors with full disclosure may exclude section 270A penalty, even where returned loss is reduced.
July 15, 2026   Case Laws Income Tax
Unascertainable TDR acquisition cost defeats capital gains computation; later deeming rules cannot retrospectively create chargeability
July 15, 2026   Case Laws Income Tax
Legal impossibility limits section 234A interest, while reverse indexation may support verified cost estimation for old property capital gains
July 15, 2026   Case Laws Income Tax
Separate maintenance agreements support business-income treatment, while replacement-loan interest may remain deductible for let-out property.
July 15, 2026   Case Laws Income Tax
Buying agency services remain business income, not technical fees, where procurement support lacks managerial, technical or consultancy character
July 15, 2026   Case Laws Income Tax
Registered property transfer fixes capital-gains tax year; absolute ownership governs assessment, with later-year tax credited appropriately
July 15, 2026   Case Laws Income Tax
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examination
July 15, 2026   Case Laws Income Tax
Slump sale prevents repeat capital-gains taxation when later conveyance registration merely perfects title to transferred undertaking assets
July 15, 2026   Case Laws Income Tax
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Method
July 15, 2026   Case Laws Benami Property
Fictitious-name benami transactions may justify attachment in the beneficial owner's account when cumulative evidence disproves genuine supply
July 15, 2026   Case Laws Customs
Sufficient cause limits late filing fees where supplementary cargo declarations reflect genuine bulk measurement and moisture variations
July 15, 2026   Case Laws Customs
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, and penalties
July 15, 2026   Case Laws Customs
Duty-free EOU input destruction under intimation attracts no duty; clarificatory amendments apply retrospectively and penalties fail absent suppression.

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Income Tax

Deduction u/s 80IA - amalgamating / demerged entity to claim any...

Successor Entities Can Claim Deductions for Amalgamations or Demergers u/s 80IA of Income Tax Act.

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Income Tax January 24, 2022 Case Laws AT
Deduction u/s 80IA - amalgamating / demerged entity to claim any deduction in the year of amalgamation/ demerger - the clarification provided in the circular for insertion of sub-section (12A) cannot be extended beyond what is unambiguously stated in the provisions of the IT Act. Sub-section (12A) simply states that from a particular date i.e. 31 March 2007 the provisions of sub-section (12) shall not apply in the specified situations. There cannot be any other meaning to such simple provision of the IT Act - sub-section (12A) of section 80IA of the IT Act, merely neutralises applicability of subsection (12) and does not disentitle the successor entities to claim deduction in accordance with section 80IA of the IT Act. - AT
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