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2025 (4) TMI 2101
Case Laws Income Tax
Cash deposits during demonetisation were explained by salary savings and bank withdrawals, preventing treatment as unexplained money.
Cash deposits made during demonetisation were not unexplained money where salary slips and bank statements evidenced past salary savings and withdrawals. Assumptions that cash could not be retained for years or deposited in multiple instalments did not rebut the supporting documentary evidence. The addition under section 69A was therefore deleted for the depositor.

2025 (5) TMI 2326
Case Laws Income Tax
Charitable-trust registration cannot be denied because Revenue records are untraceable; exemption conditions and cash deposits require fresh examination.
Section 12A registration is the statutory basis for assessing a charitable trust as a registered trust rather than as an association of persons, subject to applicable exemption conditions. Registration cannot be denied merely because original departmental records are untraceable where contemporaneous official records, attested certificates and subsequent assessment records recognise its existence and no cancellation order is shown. Exemption under sections 11 and 13 remains conditional on statutory compliance. Delay in filing Form 10B, including possible condonation under CBDT Circular No. 10/2019, and the evidentiary basis for cash deposits require examination on a complete factual record with an effective opportunity to provide supporting material.

2025 (5) TMI 2327
Case Laws Income Tax
Business-linked survey surrender is taxable at normal rates when no unexplained external source exists; enhanced rates do not retrospectively apply.
Survey surrender arising from business advances, godown construction and stock discrepancies is taxable as business income where it is recorded in the books and audited financial statements and has a direct nexus with the taxpayer's established trading activity. Sections 69 and 69C do not apply without material showing a parallel business, an outside source of funds, or another unexplained source. The enhanced tax treatment under Section 115BBE applies prospectively from assessment year 2018-19 and does not govern assessment year 2017-18; the surrendered income is therefore taxable at normal rates.

2025 (5) TMI 2328
Case Laws Income Tax
Search assessment additions supported by incriminating material remain sustainable; vexatious rectification proceedings do not excuse delayed appeals.
Section 153A additions in a completed assessment require incriminating material seized during search; where seized material and search statements indicate undisclosed income, additions remain sustainable. Income additionally declared in the return responding to a search notice may corroborate undisclosed income, and discovery of incriminating material permits other connected additions in the search assessment. Pursuit of a rectification application constitutes sufficient cause for delayed appeal only if pursued bona fide, without negligence or deliberate delay; a vexatious application does not excuse delay or require merits review.

2025 (12) TMI 1902
Case Laws Income Tax
Section 115BBE non-retrospectivity preserves normal taxation for assessment-year additions arising from demonetisation-era unexplained cash deposits.
Enhanced taxation under section 115BBE does not apply retrospectively to assessment year 2017-18; the restricted unexplained-money addition remains taxable at normal rates. Cash-intensive brick-kiln operations, including cash sales and expenditure, together with accepted presumptive taxation in the preceding year, support limiting an addition for demonetisation-period cash deposits to an estimated portion rather than treating the entire deposit as unexplained money. Illness, pandemic disruption and death may constitute sufficient cause for condoning delay in filing a first appeal.

2025 (12) TMI 1903
Case Laws Income Tax
Royalty characterization of shared-service payments fails where no intellectual-property rights, proprietary know-how, or copyright exploitation rights are transferred.
Payments for Global Brand, Global Communications, and Global Technology/Knowledge Management services under a shared-services arrangement do not constitute royalty under Article 13(3) of the India-UK tax treaty where they confer no right to use or commercially exploit trademarks, copyrights, confidential know-how, or other intellectual property. Internal access to third-party software, databases and technology tools remains use of a copyrighted article where reproduction, sublicensing, transfer and commercial-exploitation rights are absent. Routine strategy, training, coordination, advisory and communication support does not impart specialised proprietary commercial experience. The payments are therefore not chargeable to tax in India, and no withholding obligation arises under section 195.

2025 (12) TMI 1905
Case Laws Income Tax
Unexplained purchase expenditure requires proof of actual delivery; accommodation-entry information can support reassessment where the belief is independently formed.
Section 69C requires an assessee to substantiate claimed expenditure. Where credible investigation material identifies a supplier as an accommodation-entry provider, invoices, ledger confirmations and banking payments alone may not establish genuine purchases without proof of actual delivery or a satisfactory rebuttal of adverse material. Reassessment may be initiated where specific investigation information directly supports the Assessing Officer's belief that income escaped assessment, provided the belief reflects independent application of mind. The sufficiency of such material is not examined at the reopening stage, and unsubstantiated expenditure may remain included in taxable income.

2025 (12) TMI 1904
Case Laws Income Tax
Judicial discipline requires staying reassessment challenges pending resolution of connected proceedings to prevent parallel adjudication and multiplicity of litigation.
Judicial discipline required challenges to an income-tax reassessment notice and the associated approval to remain unexamined on their merits while the notice's legality was pending in connected Supreme Court proceedings. Concurrent determination could create parallel adjudication and multiplicity of litigation. Proceedings before the competent authority were therefore stayed until the Supreme Court resolved the connected matters, without any final determination of the notice or approval's validity.

PMLA / Black Money
Dated:- 19-9-2026
PTI
Enforcement Directorate sought registration of an FIR concerning alleged fraudulent payments by Cochin Minerals and Rutile Ltd to Exalogic Solutions, represented as IT consultancy fees. The request relied on evidence gathered through investigation and searches under the Prevention of Money Laundering Act. Registration remained under consideration after receipt of the Advocate General's legal opinion, with the Home Department examining the matter.

Notification No. F A 3-43/2017/1/V(29) Dated:- 18-9-2025 Madhya Pradesh SGST
Local delivery services supplied through electronic commerce operators are added to the services specified under section 9(5) of the Madhya Pradesh Goods and Services Tax Act, 2017. The added category excludes supplies where the person supplying local delivery services through the operator is liable for registration under section 22(1). The amended treatment takes effect from 22 September 2025.

Notification No. CT/8/10/2025-Sec-1-5(CT)(28) Dated:- 18-9-2025 Madhya Pradesh SGST
State tax at 6 per cent applies to intra-State supplies of fly ash bricks, aggregates and blocks; specified bricks; building bricks; and earthen or roofing tiles within designated Customs Tariff classifications. Classification follows the First Schedule to the Customs Tariff Act and associated interpretative rules, notes and explanatory notes. Undefined expressions retain their GST enactment meanings. The rate applies from 22 September 2025.

Customs & Trade
Dated:- 19-9-2026
PTI
Free Trade Agreements are presented as mechanisms for expanding cross-border partnerships, market access for entrepreneurs, and career opportunities for young persons. Youth employment is also linked to the expansion of the startup ecosystem beyond major cities and to public-sector recruitment through Rozgar Melas. Newly selected candidates are to join central government ministries, departments and organisations. Public service is framed around citizen-centred administration and decisions supporting a developed and self-reliant India.

2026 (6) TMI 1381 - ITAT BANGALORE AT
Tax treatment of VRS-labelled separation payments depends on their substantive character. Payments connected with Government-supported workforce restructuring may qualify as retrenchment compensation under section 10(10B), rather than as voluntary-retirement compensation under section 10(10C), where the special-protection requirements are satisfied. Leave encashment must be examined separately under section 10(10AA), according to employee status and the applicable conditions or notified limit. Settlement components should be segregated and supported by scheme documents, approvals, computations, and tax records.

Notification No. F A 3-23/2018/1/V(27) Dated:- 18-9-2025 Madhya Pradesh SGST
The State GST rate schedule for specified handicraft goods is revised by substituting the complete tariff-based table under section 11(1). The table assigns a 2.5% rate to most listed handcrafted and handmade goods, including articles of wood, paper, natural fibres, textiles, stone, clay, glass, base metals, furniture, toys, paintings and sculptures. Silver filigree work and handmade imitation jewellery are separately assigned a 1.5% rate. The revised schedule applies from 22 September 2025.

2014 (9) TMI 1304
Case Laws Income Tax
Capitalisation of trial-run losses and evidence-based disallowances govern depreciation and expense claims under accepted accounts.
Process-loss and business-expenditure claims require a sustainable factual basis for any disallowance: accepted accounts, absence of identified defects or unrecorded sales, and no evidence of non-business or personal use prevent ad hoc estimation. Qualifying pollution-control machinery used in business falls within the applicable depreciation framework. Trial-run losses and genuine pre-operative costs necessary to bring fixed assets into working condition form part of actual cost and attract depreciation. Separate stock or work-in-progress additions cannot rest on accepted accounts without valuation defects, particularly where the adjustment is revenue-neutral. Repair deductions require primary vouchers; failure to produce them can justify a reasonable estimated disallowance.

2018 (7) TMI 2398
Case Laws Customs
Mandatory customs-appeal pre-deposit is a statutory condition; non-compliance results in dismissal of the appeal at the threshold.
Mandatory pre-deposit is required for a customs appeal under Section 129E of the Customs Act, 1962. Failure to make the required deposit constitutes non-compliance with the statutory condition for maintaining the appeal and results in its dismissal. The deposit obligation applies to the appellant and must be met to continue the appellate process.

Notification No. F A 3-34/2017/1/V(26) Dated:- 18-9-2025 Madhya Pradesh SGST
The State Government, acting under section 11 of the Madhya Pradesh Goods and Services Tax Act, 2017 on Council recommendations, amends the Table at serial number 1. The entry in column (4) is substituted with "9%". The amendment retains the existing serial number and table location and comes into force on 22 September 2025.

2026 (9) TMI 1370
Case Laws Income Tax
Delayed audit-report filing cannot defeat charitable exemption when the prescribed form is furnished during appellate proceedings and delay is condonable.
Exemption under Section 11 remains available to a registered charitable trust where its return is filed within the extended period under Section 139(4) and Form 10B is furnished during appellate proceedings, even if the form follows processing under Section 143(1). The audit-report requirement under Section 12A(1)(b) permits condonation of delayed electronic filing in these circumstances. A balanced, equitable and judicious approach applies; strict compliance does not justify rejecting the exemption merely because Form 10B was not filed before return processing. The delayed filing is condoned, requiring the exemption claim to be allowed.

Circular No. CCT/26-4/2017-18/E/1872 Dated:- 26-10-2021 Goa SGST Dated:- 26-10-2021 Goa SGST
Intermediary services require at least three parties: two principals involved in a main supply and a third party making a separate ancillary supply by arranging or facilitating it. The role must be subsidiary and comparable to that of a broker or agent. A person supplying the main goods, services, or securities, wholly or partly, on its own account on a principal-to-principal basis is excluded. Subcontractors performing all or part of the substantive main service are not intermediaries, even where they interact with the principal supplier's customer.

2026 (7) TMI 783 - ITAT MUMBAI AT
Renewal of section 12AB registration for a charitable hospital depends on genuine activities in furtherance of medical relief, application of income and assets to charitable objects, and compliance with other laws only where material to those objects. Receipts, premium facilities, tariff differentials, sophisticated infrastructure and professional management do not alone negate charitable status. Other-law non-compliance requires attention to the specified-violation framework and competent regulatory determinations. Retrospective cancellation is distinct from refusing renewal and requires an independent statutory and factual foundation, with reasonable opportunity of hearing.

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