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2025 (7) TMI 2087
Case Laws Income Tax
Delayed audit-report filing is a curable defect, preserving charitable exemption during summary income-tax return processing.
Timely electronic filing of Form 10B under Section 12A(b) is treated as a directory requirement, with delayed filing regarded as a curable procedural defect. In light of Circular No. 10/2019 and the debatable nature of the requirement, delay in uploading the audit report may be condoned. Exemption under Section 11 should not be denied during summary processing of a return under Section 143(1) solely because Form 10B was uploaded after the prescribed due date.

2025 (8) TMI 1888
Case Laws Income Tax
Unsecured loan evidence defeats cash-credit additions where identity, capacity and transaction genuineness are established through banking records.
Documentary and banking evidence establishing creditor identity, financial capacity and transaction genuineness discharges the primary burden for unsecured loans; uncorroborated third-party reports, untested statements and unserved summons cannot sustain cash-credit additions without a live nexus, rebuttal evidence or cross-examination. The loan additions and consequential interest disallowances were therefore deleted. A bilateral English instrument lacking customary negotiable Hundi characteristics, where funds moved through banking channels, does not attract section 69D; the related addition was deleted. Business-loss carry-forward remains subject to verification of statutory eligibility, with eligible losses to be allowed.

2025 (10) TMI 1497
Case Laws Income Tax
Incriminating material requirement bars unsecured-loan additions in unabated search assessments where seized records merely reflect disclosed book entries.
In unabated assessments under sections 153A and 153C, additions concerning unsecured loans must rest on incriminating material found during the search and directly related to the proposed addition. Post-search enquiries, lender-related information and a standalone statement recorded during search do not supply that foundation. Seized records that merely reflect loans already recorded in regular books and disclosed in the original return are not incriminating. A notation suggesting repayment cannot establish cash repayment without corroborative evidence or lender enquiry. Accordingly, unsecured-loan additions cannot be sustained solely through post-search challenges to lender genuineness or cash-credit evidence.

2025 (12) TMI 1933
Case Laws Income Tax
Faceless reassessment allocation bars jurisdictional officers from issuing notices and invalidates consequential assessments when bypassed.
Section 124(3) limits challenges to territorial jurisdiction but does not bar objections that an officer lacked inherent statutory authority to initiate reassessment. Statutory jurisdiction cannot be created by participation, acquiescence, or waiver; proceedings initiated without such authority are void. Section 151A and the faceless reassessment scheme require automated allocation and issuance of reassessment notices through the Faceless Assessing Officer, excluding concurrent jurisdiction of a Jurisdictional Assessing Officer. An order under Section 148A(d), notice under Section 148, and consequential assessment initiated outside that mandatory mechanism lack jurisdiction and are invalid.

2025 (12) TMI 1934
Case Laws Income Tax
Unexplained Bullion: Jewellery Search Limits Do Not Cover Unsubstantiated Melted Jewellery Claims for Tax Addition
Unexplained bullion claimed to have arisen from melted old jewellery remains unsubstantiated where post-search affidavits and subsequent jeweller confirmations do not identify the jewellery, specify the melting date, or provide contemporaneous records such as weighing slips and melting charges. CBDT jewellery limits applicable during search do not extend to bullion, particularly where the benefit has already been granted for jewellery found with family members. The bullion addition was therefore sustained as unexplained money under the Income-tax Act.

2026 (8) TMI 1863
Case Laws Income Tax
Section 54 exemption for multiple homes remained available before the prospective single-home amendment, subject to timing verification.
Section 54(1), as applicable to Assessment Year 2013-14, treated the expression "a residential house" as capable of covering qualifying investments in more than one residential property, including properties at different locations. The Finance (No. 2) Act, 2014 substitution of "one residential house" took effect from 1 April 2015 and did not restrict claims for the earlier assessment year. As a beneficial provision encouraging house purchase, Section 54(1) required liberal interpretation. Qualifying investments in Heritage One and Adani M2K were eligible for exemption, while the La Lagune claim depended on verification of the stipulated investment-time condition.

2025 (10) TMI 1496
Case Laws Income Tax
Charitable registration requires examining overall public benefit, not merely member-focused clauses or exemption restrictions at assessment.
Registration under section 12AB requires examination of whether a trust's objects are charitable, including advancement of general public utility. Clauses benefiting members do not alone establish that the objects lack public benefit where the stated purposes include industry coordination, research, training, information dissemination, public infrastructure and community development. Section 13(1)(b) governs entitlement to exemption under sections 11 and 12 at assessment and, by itself, does not justify refusal of registration. The absence of religious objects and the overall public character of the purposes support fresh consideration of registration.

2026 (7) TMI 2045
Case Laws Income Tax
Substantial question of law absent where concurrent findings sustained unexplained gold-bar addition despite explained ornaments.
Addition for four 24-carat gold bars found in a locker remained sustained because concurrent findings treated them as unexplained and raised no substantial question of law under Section 260A. Gold ornaments in the locker were accepted as explained. The Section 260A challenge therefore did not warrant interference with the addition relating to the gold bars.

2025 (8) TMI 1887
Case Laws GST
Contractual tax-allocation clauses bar GST reimbursement, while private disputes with arbitration clauses fall outside writ jurisdiction.
Contractual tax-allocation clauses treating tender prices as inclusive of taxes and barring claims arising from changes in tax structure place GST introduced after 1 July 2017 outside reimbursement, notwithstanding a specific provision concerning service tax. A disputed GST reimbursement claim arising solely from a private commercial contract, involving interpretation of contractual terms and factual questions, lacks the public-law element required for Article 226 review. Where the contract contains an arbitration clause, the claim must proceed through the agreed dispute-resolution mechanism or a competent civil forum rather than writ jurisdiction.

2025 (10) TMI 1494
Case Laws GST
Review jurisdiction under the CPC cannot reopen contractual writ disputes through reappreciation of facts or merits.
Review under Order XLVII Rule 1 of the Code of Civil Procedure is limited to an error apparent on the face of the record or an overlooked material fact affecting the decision. It cannot be used to reappreciate facts or reargue the merits. Where a writ claim has been treated as contractual and civil-court and arbitral remedies remain available, a review or recall request must identify an apparent error or other sufficient review ground. Grounds seeking only reconsideration on merits do not justify review or recall.

Customs, DGFT & SEZ
Dated:- 23-10-2026
Engineering-export strategy development focuses on stronger use of free trade pacts, market access, competitive raw-material availability and resilient supply chains. Input-cost volatility, supply-chain disruptions, global overcapacity, trade-protective measures, sustainability-related requirements and climate-linked market-access conditions affect export competitiveness. Quality Control Orders require an evidence-based assessment of covered sectors and products, their rationale and industry impact, supported by a comprehensive white paper and panel-wide feedback for policy deliberation.

Circular No. 193/5/2023-GST Dated:- 28-11-2023 Jharkhand SGST Dated:- 28-11-2023 Jharkhand SGST
ITC differences between FORM GSTR-3B and FORM GSTR-2A for 1 April 2019 to 31 December 2021 must be assessed under the applicable rule 36(4) cap and the supplier-tax-payment condition. Additional unmatched ITC was restricted to 20% from 9 October 2019, 10% during 2020, and 5% during 2021, subject to verification and requisite certificates. Claims beyond the applicable cap are not admissible. From 1 January 2022, ITC requires supplier reporting in FORM GSTR-1 or through the Invoice Furnishing Facility and communication in FORM GSTR-2B.

A. Chemical & Allied Products
Standard Input-Output Norm A-3718 governs manufacture of Clobetasol Propionate BP/EP/USP for export. It identifies Betamethasone 17-Propionate as the permitted import input for the specified export product and fixes the applicable input-output proportion. Applicants must ensure that goods sought to be imported, and goods actually imported, are those used or required in manufacturing the resultant export product.

A. Chemical & Allied Products
Standard Input-Output Norm No. A-3717 under the Foreign Trade Policy fixes the permitted import input for manufacturing Doxycycline Tablets, USP 100 MG 500 S. For each unit of the export product, Doxycycline USP (Monohydrate) is specified at 109.68 mg. Applicants must ensure that goods sought for import and actually imported are used or required in the exported product.

A. Chemical & Allied Products
Standard Input-Output Norm A-3716 fixes Doxycycline USP (Monohydrate) as the imported input for manufacturing Doxycycline Tablets, USP 100 MG 50 S. Applicants must ensure that imported goods are used or required in producing the specified export product.

A. Chemical & Allied Products
Standard Input-Output Norm A-3715 specifies the input requirement for export manufacture of Doxycycline Tablets, USP 50 MG 100 S. For each number of the export product, the specified import input is Doxycycline USP (Monohydrate) at 54.84 mg. Applicants must ensure that goods sought and actually imported are those used or required in the exported product.

Notification No. 22732-FIN-CT1-TAX-5/2015/F. Dated:- 11-8-2023 Orissa SGST
Arrear dues comprising tax, interest and penalty between Rs. 5,001 and Rs. 25,000 in each case, outstanding up to 31 March 2023, are written off under specified sales tax, value added tax, central sales tax and entertainment tax regimes. The write-off excludes arrears concerning specified petroleum goods and liquor for human consumption, as well as arrears under entry tax and professional tax laws. It addresses low-value recovery cases where recovery costs and administrative effort may exceed the arrear amount.

Circular No. 28 Dated:- 23-10-2026 Circular Dated:- 23-10-2026 Circular
Powers to compound specified FEMA contraventions concerning overseas investments, borrowing and lending, and guarantees are delegated to select Regional Offices. Overseas investment applications must be filed according to the Unique Identification Number assigned to the relevant foreign entity, joint venture, or wholly owned subsidiary; cases without a UIN go to the Cell for Effective Implementation of FEMA at the Central Office. Borrowing, lending, and guarantee applications follow Regional Office jurisdiction based on the registered office or domicile, subject to the overseas direct investment exception.

Purchase of taxable goods from an agriculturist or unregistered dealer, where reverse charge does not apply, is addressed as a normal purchase entry without GST in Tally Prime. The issue of whether the purchase value requires disclosure in GSTR-3B is raised, without a specific filing treatment being provided.

Circular No. 36/2026-27 Dated:- 23-10-2026 Public Notice Dated:- 23-10-2026 Public Notice
Four new Standard Input-Output Norms under Chemical and Allied Products prescribe import-product and quantity entitlements for specified doxycycline tablet and clobetasol propionate exports. The norms allow stated quantities of doxycycline USP (monohydrate) for three doxycycline tablet variants and betamethasone 17-propionate for clobetasol propionate. They facilitate expeditious issuance of Advance Authorisations by Regional Authorities and uniform application of input-output norms.

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