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    March 10, 2026   Case Laws Income Tax
    Unexplained cash balances treated as income where alleged cash gifts lack independent proof of donor source and capacity.
    March 10, 2026   Case Laws Income Tax
    Survey disclosure accepted in assessment bars penalty for concealment; income included in return prevents penalty application.
    March 10, 2026   Case Laws Income Tax
    Mutuality principle exempts member subscriptions; taxable interest may be appropriated to meet bona fide member payments before assessment.
    March 10, 2026   Case Laws Income Tax
    Carbon credit definition limits concessional tax; RECs are distinct and not eligible for concessional rate or generation deduction.
    March 10, 2026   Case Laws Income Tax
    Valuation Method Choice under Rule 11UA bars AO from replacing taxpayer's DCF with NAV; addition deleted.
    March 10, 2026   Case Laws Income Tax
    Revision under Section 263 requires absence of application of mind; mere disagreement or demand for DVO referral is insufficient, revision set aside.
    March 10, 2026   Case Laws Income Tax
    Transfer Pricing adjustment sustained for unilateral loan write off, while R&D costs allowed as ordinary business expenditure.
    March 10, 2026   Case Laws Income Tax
    Transfer Pricing Comparability: exclude functionally dissimilar comparable; recompute ALP and remit excise exemption capitality for AO verification.
    March 10, 2026   Case Laws Income Tax
    Capital Gains: allotment on surrender of tenancy rights treated as consideration for transfer, not residuary income, enabling residential exemption.
    March 10, 2026   Case Laws Income Tax
    TDS Credit Recognition: penalty under section 270A deleted where challan proof led to no outstanding demand.
    March 10, 2026   Case Laws Income Tax
    Approval requirement under section 151(2) - reassessment beyond three years invalid; notice and penalties quashed.
    March 10, 2026   Case Laws Income Tax
    Dependent Agent Permanent Establishment: habitual authority to conclude contracts must be proven; distributors as independent resellers defeated DAPE.
    March 10, 2026   Case Laws Income Tax
    Immunity under section 270AA denied if AO fails reasoned rejection on application; penalty under 270A quashed.
    March 10, 2026   Case Laws Income Tax
    Unexplained income: bank payment records and TDS evidence can rebut tax additions, leading to deletion on proof of payment.
    March 10, 2026   Case Laws Income Tax
    Unexplained Money under Section 69A: deletions upheld where withdrawals traced to disclosed bank accounts and books not rejected.
    March 10, 2026   Case Laws Income Tax
    Depreciation entitlement for concession assets recognised despite non ownership, resulting in denial of revenue appeal and allowance.
    March 10, 2026   Case Laws Income Tax
    Reasonable Cause Defense requires contemporaneous medical evidence; absence upheld penalty for non compliance with statutory notices.
    March 10, 2026   Case Laws Income Tax
    Depreciation of goodwill arising on amalgamation is allowable because such goodwill is an intangible asset and deductible.
    March 10, 2026   Case Laws Income Tax
    Absence of mens rea prevents tax penalty where an inadvertent clerical misclassification by a tax consultant occurred.
    March 10, 2026   Case Laws Customs
    Mis-declaration and Concealment: confiscation affirmed, transaction value re-determined and mandatory penalty sustained; redemption allowed on payment...
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March 10, 2026   Case Laws Income Tax
Unexplained cash balances treated as income where alleged cash gifts lack independent proof of donor source and capacity.
March 10, 2026   Case Laws Income Tax
Survey disclosure accepted in assessment bars penalty for concealment; income included in return prevents penalty application.
March 10, 2026   Case Laws Income Tax
Mutuality principle exempts member subscriptions; taxable interest may be appropriated to meet bona fide member payments before assessment.
March 10, 2026   Case Laws Income Tax
Carbon credit definition limits concessional tax; RECs are distinct and not eligible for concessional rate or generation deduction.
March 10, 2026   Case Laws Income Tax
Valuation Method Choice under Rule 11UA bars AO from replacing taxpayer's DCF with NAV; addition deleted.
March 10, 2026   Case Laws Income Tax
Revision under Section 263 requires absence of application of mind; mere disagreement or demand for DVO referral is insufficient, revision set aside.
March 10, 2026   Case Laws Income Tax
Transfer Pricing adjustment sustained for unilateral loan write off, while R&D costs allowed as ordinary business expenditure.
March 10, 2026   Case Laws Income Tax
Transfer Pricing Comparability: exclude functionally dissimilar comparable; recompute ALP and remit excise exemption capitality for AO verification.
March 10, 2026   Case Laws Income Tax
Capital Gains: allotment on surrender of tenancy rights treated as consideration for transfer, not residuary income, enabling residential exemption.
March 10, 2026   Case Laws Income Tax
TDS Credit Recognition: penalty under section 270A deleted where challan proof led to no outstanding demand.
March 10, 2026   Case Laws Income Tax
Approval requirement under section 151(2) - reassessment beyond three years invalid; notice and penalties quashed.
March 10, 2026   Case Laws Income Tax
Dependent Agent Permanent Establishment: habitual authority to conclude contracts must be proven; distributors as independent resellers defeated DAPE.
March 10, 2026   Case Laws Income Tax
Immunity under section 270AA denied if AO fails reasoned rejection on application; penalty under 270A quashed.
March 10, 2026   Case Laws Income Tax
Unexplained income: bank payment records and TDS evidence can rebut tax additions, leading to deletion on proof of payment.
March 10, 2026   Case Laws Income Tax
Unexplained Money under Section 69A: deletions upheld where withdrawals traced to disclosed bank accounts and books not rejected.
March 10, 2026   Case Laws Income Tax
Depreciation entitlement for concession assets recognised despite non ownership, resulting in denial of revenue appeal and allowance.
March 10, 2026   Case Laws Income Tax
Reasonable Cause Defense requires contemporaneous medical evidence; absence upheld penalty for non compliance with statutory notices.
March 10, 2026   Case Laws Income Tax
Depreciation of goodwill arising on amalgamation is allowable because such goodwill is an intangible asset and deductible.
March 10, 2026   Case Laws Income Tax
Absence of mens rea prevents tax penalty where an inadvertent clerical misclassification by a tax consultant occurred.
March 10, 2026   Case Laws Customs
Mis-declaration and Concealment: confiscation affirmed, transaction value re-determined and mandatory penalty sustained; redemption allowed on payment of fines.

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Income Tax

A reassessment notice issued beyond three years from the end of...

Invalid reassessment sanction beyond three years vitiates notice and assessment where approval is taken from the wrong authority.

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Income Tax May 2, 2026 Case Laws AT
A reassessment notice issued beyond three years from the end of the relevant assessment year required prior approval from the higher authority specified under section 151(ii), not the Principal Commissioner. As the sanction was obtained from an incompetent authority, the approval was invalid and contrary to law. The Tribunal treated this defect as fatal and quashed both the reassessment notice and the consequential assessment order.
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Acts Income Tax
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