Just a moment...

⚠ ✕
❮ Top
☎ Help
☰
×

By creating an account you can:

Logo TaxTMI
Keyword Search :
AI Tools : New
Ask tax questions in natural language. Powered by AI trained on the TaxTMI legal database. Use AI Tools ➞
Call Us / Help / Feedback✕

Contact Us At :

✉ E-mail: [email protected]

✆ Call / WhatsApp at: +91 99117 96707

For more information, Check Contact Us

FAQs :

To know Frequently Asked Questions, Check FAQs

Most Asked Video Tutorials :

For more tutorials, Check Video Tutorials

Submit Feedback/Suggestion :

Email :
Please provide your email address so we can follow up on your feedback.
Category :
Description :
Min 15 characters 0/2000
Make Most of Text Search ✕
  1. Checkout this video tutorial: How to search effectively on TaxTMI.
  2. Put words in double quotes for exact word search, eg: "income tax"
  3. Avoid noise words such as : 'and, of, the, a'
  4. Sort by Relevance to get the most relevant document.
  5. Press Enter to add multiple terms/multiple phrases, and then click on Search to Search.
    6. Text Search
  6. The system will try to fetch results that contains ALL your words.
  7. Once you add keywords, you'll see a new 'Search In' filter that makes your results even more precise.
    8. Text Search
╳
Add to...
You have not created any category. Kindly create one to bookmark this item!
✕
Create New Category
Hide
Title :
Description :
❮❮ Hide
❮ Default View
Expand ❯❯
Close ✕
🔎 Highlights - Adv. Search ❯
TEXT SEARCH:

Press 'Enter' to add multiple search terms. Rules for Better Search

Search In:
Main Text + AI Text ❯
  • Main Text
  • Main Text + AI Text
  • AI Text
Law:
---- All Laws---- ❯
  • ---- All Laws----
  • Income Tax
  • Direct Taxes
  • Benami Property
  • Central GST Laws
  • SGST - State GST Laws
  • Customs
  • FTP - Foreign Trade Policy
  • SEZ - Special Economic Zone
  • FEMA - Foreign Exchange Management
  • Companies Law
  • SEBI - Securities & Exchange Board of India
  • IBC - Insolvency and Bankruptcy
  • Law of Competition
  • PMLA - Money-Laundering
  • Indian Laws
  • Bill / Finance Bills
  • Wealth Tax
  • Service Tax
  • Central Excise
  • VAT / Sales Tax
Month:
---- All Months ---- ❯
  • ---- All Months ----
  • January
  • February
  • March
  • April
  • May
  • June
  • July
  • August
  • September
  • October
  • November
  • December
Year:
---- All Years ---- ❯
  • ---- All Years ----
  • 2026
  • 2025
  • 2024
  • 2023
  • 2022
  • 2021
  • 2020
  • 2019
  • 2018
  • 2017
  • 2016
  • 2015
  • 2014
  • 2013
  • 2012
  • 2011
Sort By: ?
In Sort By 'Default', exact matches for text search are shown at the top, followed by the remaining results in their regular order.
Relevance Default Date
    August 26, 2026   Case Laws GST
    GST demand limitation bars late notices unless extended recovery is supported by foundational fraud or suppression facts.
    August 26, 2026   Case Laws GST
    Fair hearing in budgetary support claims requires an opportunity to explain input tax credit declaration discrepancies before determination.
    August 26, 2026   Case Laws GST
    Bail in fraudulent input tax credit allegations granted where investigation was nearly complete and further custody unnecessary.
    August 26, 2026   Case Laws GST
    Input tax credit time limits: Section 16(5) preserves entitlement where the relevant return was filed before the cut-off.
    August 26, 2026   Case Laws Income Tax
    GST refund mismatch evidence remanded for fresh review, while reconciled trade payables defeat unexplained cash credit addition.
    August 26, 2026   Case Laws Income Tax
    Competent reassessment sanction is jurisdictional; invalid approval nullifies reassessment, while unproved trading turnover cannot trigger audit penal...
    August 26, 2026   Case Laws Income Tax
    Additional evidence in commission claims requires fresh consideration when directly relevant, while unsupported uniform interest estimates fail.
    August 26, 2026   Case Laws Income Tax
    Copyrighted software use without copyright rights is not royalty; equipment supplies remain outside technical-service fees.
    August 26, 2026   Case Laws Income Tax
    Income Disclosure Scheme immunity and search-material requirements barred further share-transaction additions in unabated assessments under section 15...
    August 26, 2026   Case Laws Income Tax
    Capital-gains exemption for charitable trusts extends to scheduled-bank fixed deposits and qualifying savings balances from sale proceeds.
    August 26, 2026   Case Laws Income Tax
    Pecuniary jurisdiction for statutory tax notices makes assessments void when CBDT income-limit instructions are breached
    August 26, 2026   Case Laws Income Tax
    Bogus-purchase additions require transaction-specific evidence; supplier deregistration and later non-compliance alone cannot displace documented purc...
    August 26, 2026   Case Laws Income Tax
    Foreign leave travel concession taxation requires employer tax deduction, with mandatory interest for non-deduction and limited relief routes.
    August 26, 2026   Case Laws Income Tax
    TNMM Benchmarking Bars Separate AMP Adjustment Where Interlinked Transactions Are Already Accepted at Arm's Length
    August 26, 2026   Case Laws Income Tax
    Foreign-currency loan benchmarking follows LIBOR-based rates, while delayed-receivable and exempt-income expense adjustments fail on the stated facts.
    August 26, 2026   Case Laws Income Tax
    Inadequate inquiry under section 263 requires proven inquiry failure, not merely a different revisional view on share gains.
    August 26, 2026   Case Laws Income Tax
    Resale Price Method supports foreign tested parties where merchant traders bear minimal commercial risks in back-to-back sales.
    August 26, 2026   Case Laws Customs
    Expiry of the show-cause notice period barred further proceedings and limited warehousing charges on release of detained gold articles.
    August 26, 2026   Case Laws Customs
    Toy balloon tariff classification: functional heading prevails over residual rubber and festive article headings, supporting penalties for deliberate ...
    August 26, 2026   Case Laws Customs
    Customs valuation using comparable contemporaneous imports can displace declared value, while missing speaking orders require pursuit before competent...
❮
❯
❯❯
Maximize Maximize Maximize
0 / 200
Expand Note
Add to Folder

No Folders have been created

+

Are you sure you want to delete "My most important" ?

NOTE:

Open Link
Highlights
Showing Results for :
Reset Filters
Results Found:
Show All Summaries Hide All Summaries
August 26, 2026   Case Laws GST
GST demand limitation bars late notices unless extended recovery is supported by foundational fraud or suppression facts.
August 26, 2026   Case Laws GST
Fair hearing in budgetary support claims requires an opportunity to explain input tax credit declaration discrepancies before determination.
August 26, 2026   Case Laws GST
Bail in fraudulent input tax credit allegations granted where investigation was nearly complete and further custody unnecessary.
August 26, 2026   Case Laws GST
Input tax credit time limits: Section 16(5) preserves entitlement where the relevant return was filed before the cut-off.
August 26, 2026   Case Laws Income Tax
GST refund mismatch evidence remanded for fresh review, while reconciled trade payables defeat unexplained cash credit addition.
August 26, 2026   Case Laws Income Tax
Competent reassessment sanction is jurisdictional; invalid approval nullifies reassessment, while unproved trading turnover cannot trigger audit penalty.
August 26, 2026   Case Laws Income Tax
Additional evidence in commission claims requires fresh consideration when directly relevant, while unsupported uniform interest estimates fail.
August 26, 2026   Case Laws Income Tax
Copyrighted software use without copyright rights is not royalty; equipment supplies remain outside technical-service fees.
August 26, 2026   Case Laws Income Tax
Income Disclosure Scheme immunity and search-material requirements barred further share-transaction additions in unabated assessments under section 153A.
August 26, 2026   Case Laws Income Tax
Capital-gains exemption for charitable trusts extends to scheduled-bank fixed deposits and qualifying savings balances from sale proceeds.
August 26, 2026   Case Laws Income Tax
Pecuniary jurisdiction for statutory tax notices makes assessments void when CBDT income-limit instructions are breached
August 26, 2026   Case Laws Income Tax
Bogus-purchase additions require transaction-specific evidence; supplier deregistration and later non-compliance alone cannot displace documented purchases.
August 26, 2026   Case Laws Income Tax
Foreign leave travel concession taxation requires employer tax deduction, with mandatory interest for non-deduction and limited relief routes.
August 26, 2026   Case Laws Income Tax
TNMM Benchmarking Bars Separate AMP Adjustment Where Interlinked Transactions Are Already Accepted at Arm's Length
August 26, 2026   Case Laws Income Tax
Foreign-currency loan benchmarking follows LIBOR-based rates, while delayed-receivable and exempt-income expense adjustments fail on the stated facts.
August 26, 2026   Case Laws Income Tax
Inadequate inquiry under section 263 requires proven inquiry failure, not merely a different revisional view on share gains.
August 26, 2026   Case Laws Income Tax
Resale Price Method supports foreign tested parties where merchant traders bear minimal commercial risks in back-to-back sales.
August 26, 2026   Case Laws Customs
Expiry of the show-cause notice period barred further proceedings and limited warehousing charges on release of detained gold articles.
August 26, 2026   Case Laws Customs
Toy balloon tariff classification: functional heading prevails over residual rubber and festive article headings, supporting penalties for deliberate misclassification.
August 26, 2026   Case Laws Customs
Customs valuation using comparable contemporaneous imports can displace declared value, while missing speaking orders require pursuit before competent authorities.

Highlights

Back

All Highlights

Showing Results for :
Reset Filters
No Records Found

Highlights

Home › Highlights › Income Tax › 2024 › July, 2024 › This
Back

All Highlights

whatsapp Join Channel
Showing Results for : Reset Filters
Income Tax

Penalty u/s 271(1)(c) was imposed for disallowance of...

Depreciation on non-compete fees allowed. Divergent HC views. Supreme Court to decide. Penalty u/s 271(1)(c) can't be imposed.

Contents
Summary
Note

Note

-

Bookmark

Print

Print

Print Options

Income Tax July 26, 2024 Case Laws AT
Penalty u/s 271(1)(c) was imposed for disallowance of depreciation on non-compete fees. The CIT(A) relied on Sharp Business System [2012 (11) TMI 324 - Delhi High Court], which is under challenge before the Supreme Court. Pepsico India Holding Pvt. Ltd. [2024 (4) TMI 1154 - Delhi High Court] allowed depreciation on non-compete fees after considering Sharp Business System. Different High Courts have divergent views on allowability of depreciation on non-compete fees, and the matter is pending before the Supreme Court. Considering the contentious issue, provisions of Section 271(1)(c) cannot be attracted. Assessee's appeal allowed.
View Source View

Topics

Acts Income Tax
Next ➔