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    July 22, 2026   Case Laws Income Tax
    Unexplained cash-credit additions require consideration of lender-source evidence and relevant precedents before a fresh determination.
    July 22, 2026   Case Laws Income Tax
    Foreign tax credit claims require verification, while genuine lack of awareness of electronic appeals can justify condoning delay.
    July 22, 2026   Case Laws Income Tax
    Fees for technical services treatment of software and SaaS depends on human intervention and specialised customer-specific services.
    July 22, 2026   Case Laws Income Tax
    Receipt of immovable property requires actual possession or enjoyment; redevelopment allotments exchanged for tenancy rights fall outside deemed incom...
    July 22, 2026   Case Laws Income Tax
    Belated tax audit reporting may be a technical breach where the report was considered during reassessment without additions.
    July 22, 2026   Case Laws Income Tax
    Commission income in principal-agent sales is estimated on limited mark-up, while agency receipts cannot be treated as turnover.
    July 22, 2026   Case Laws Income Tax
    Section 54 exemption covers a multi-floor home acquired as one property, while unsupported land valuation rejection requires recomputation.
    July 22, 2026   Case Laws Income Tax
    Joint development agreements trigger capital gains on development possession, while multiple allotted flats may receive residential exemption.
    July 22, 2026   Case Laws Income Tax
    Bona fide Form 26QB PAN errors require verification and manual TDS credit rectification; factually flawed reassessment notices fail.
    July 22, 2026   Case Laws Income Tax
    Section 80P deduction covers Souharda credit societies, including qualifying surplus-deposit interest, subject to member KYC verification for cash dep...
    July 22, 2026   Case Laws Income Tax
    Unsupported cost estimation fails, while timely residential-property investment preserves section 54F relief despite procedural deposit non-compliance...
    July 22, 2026   Case Laws Income Tax
    Bona fide excessive donation exemption claims with full disclosure do not justify penalty for under-reporting or misreporting income.
    July 22, 2026   Case Laws Income Tax
    Joint development agreement taxability requires factual scrutiny of revenue accrual, possession, refundable deposits, and stock-in-trade character.
    July 22, 2026   Case Laws Income Tax
    Mandatory scrutiny notice by the assessing officer is essential; assessment without it is jurisdictionally invalid and consequential proceedings fail.
    July 22, 2026   Case Laws Income Tax
    Unsecured loan genuineness and sufficient own funds defeated cash-credit additions and interest disallowance on interest-free group advances.
    July 22, 2026   Case Laws Income Tax
    Political donation genuineness requires credible proof beyond banking records when surrounding circumstances indicate possible accommodation entries.
    July 22, 2026   Case Laws Income Tax
    Rectification limitation under section 154 is jurisdictional: delayed applications cannot be entertained without statutory power to condone delay.
    July 22, 2026   Case Laws Income Tax
    Assessee-selected NAV valuation method limits tax scrutiny; share-premium addition cannot rest on alternative valuation or alleged FEMA breaches.
    July 22, 2026   Case Laws Income Tax
    Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallo...
    July 22, 2026   Case Laws Income Tax
    Voluntary retirement scheme receipts treated as capital where resignation, not employer termination, governed cessation of employment.
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July 22, 2026   Case Laws Income Tax
Unexplained cash-credit additions require consideration of lender-source evidence and relevant precedents before a fresh determination.
July 22, 2026   Case Laws Income Tax
Foreign tax credit claims require verification, while genuine lack of awareness of electronic appeals can justify condoning delay.
July 22, 2026   Case Laws Income Tax
Fees for technical services treatment of software and SaaS depends on human intervention and specialised customer-specific services.
July 22, 2026   Case Laws Income Tax
Receipt of immovable property requires actual possession or enjoyment; redevelopment allotments exchanged for tenancy rights fall outside deemed income.
July 22, 2026   Case Laws Income Tax
Belated tax audit reporting may be a technical breach where the report was considered during reassessment without additions.
July 22, 2026   Case Laws Income Tax
Commission income in principal-agent sales is estimated on limited mark-up, while agency receipts cannot be treated as turnover.
July 22, 2026   Case Laws Income Tax
Section 54 exemption covers a multi-floor home acquired as one property, while unsupported land valuation rejection requires recomputation.
July 22, 2026   Case Laws Income Tax
Joint development agreements trigger capital gains on development possession, while multiple allotted flats may receive residential exemption.
July 22, 2026   Case Laws Income Tax
Bona fide Form 26QB PAN errors require verification and manual TDS credit rectification; factually flawed reassessment notices fail.
July 22, 2026   Case Laws Income Tax
Section 80P deduction covers Souharda credit societies, including qualifying surplus-deposit interest, subject to member KYC verification for cash deposits.
July 22, 2026   Case Laws Income Tax
Unsupported cost estimation fails, while timely residential-property investment preserves section 54F relief despite procedural deposit non-compliance.
July 22, 2026   Case Laws Income Tax
Bona fide excessive donation exemption claims with full disclosure do not justify penalty for under-reporting or misreporting income.
July 22, 2026   Case Laws Income Tax
Joint development agreement taxability requires factual scrutiny of revenue accrual, possession, refundable deposits, and stock-in-trade character.
July 22, 2026   Case Laws Income Tax
Mandatory scrutiny notice by the assessing officer is essential; assessment without it is jurisdictionally invalid and consequential proceedings fail.
July 22, 2026   Case Laws Income Tax
Unsecured loan genuineness and sufficient own funds defeated cash-credit additions and interest disallowance on interest-free group advances.
July 22, 2026   Case Laws Income Tax
Political donation genuineness requires credible proof beyond banking records when surrounding circumstances indicate possible accommodation entries.
July 22, 2026   Case Laws Income Tax
Rectification limitation under section 154 is jurisdictional: delayed applications cannot be entertained without statutory power to condone delay.
July 22, 2026   Case Laws Income Tax
Assessee-selected NAV valuation method limits tax scrutiny; share-premium addition cannot rest on alternative valuation or alleged FEMA breaches.
July 22, 2026   Case Laws Income Tax
Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallowed.
July 22, 2026   Case Laws Income Tax
Voluntary retirement scheme receipts treated as capital where resignation, not employer termination, governed cessation of employment.

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Home › Highlights › Income Tax › 2022 › November, 2022 › This
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Income Tax

Reopening of assessment u/s 147 - Reason to believe - Addition...

Challenge to Income Tax Reassessment u/s 147: Insufficient Evidence and Vague Justification for Income Escapement.

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Income Tax November 21, 2022 Case Laws AT
Reopening of assessment u/s 147 - Reason to believe - Addition u/s.68 - unsecured loans obtained - the nexus between the alleged material, i.e. the investigation report of the CBI, and the belief of escapement of income from assessment under section 147 of the Act is missing and thus renders the reasons to be reasons to suspect for making further investigation - AO are not only vague but also lack the vital link - AT
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Acts Income Tax
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