Exemption for enhanced compensation on compulsory acquisition of agricultural land - Long-term capital gain on sale of office premises - correction of disclosed classification without revised return Eligibility of enhanced compensation received on compulsory acquisition of land for exemption u/s 10(37) - Agricultural operations evidenced by revenue records - HELD THAT: - The conveyance documents and Adangal records established that the acquired lands were agricultural lands and that agricultu... ... ...

Revision under section 263 for non-initiation of penalty under section 271D - AO's jurisdiction to initiate penalty under section 271D Validity of revision u/s 263 on the ground that the Assessing Officer did not record satisfaction for initiating penalty proceedings for alleged acceptance of cash loans or payments in contravention of section 269SS - HELD THAT: - Before 1 April 2025, penalty under section 271D could be imposed only by the Joint/Additional Commissioner and not by the Asses... ... ...

Deductibility of RBI regulatory penalty - Section 14A disallowance on bank investments held as stock-in-trade - Depreciation on bank investments under ICDS VIII and RBI guidelines - ESOP expenditure as revenue expenditure Deductibility of RBI regulatory penalty - Explanation 1 to section 37(1) - Allowability of the monetary levy imposed by RBI for regulatory non-compliance relating to lending to NBFCs - HELD THAT: - The statutory source of RBI's power to impose a monetary levy is not, by ... ... ...

Credit of tax deducted at source despite deductor's default - Bar against direct demand on deductee Entitlement to credit of tax deducted at source from rental income where the tenant-deductor failed to deposit the deducted tax with the Central Government - HELD THAT: - Where tax had been deducted by the tenant from the assessee's rental income, the deductor's failure to deposit it could not affect the assessee's declaration of income or justify denial of TDS credit. The statu... ... ...

Deduction of interest on investments with a co-operative bank - Primary Agricultural Credit Society - Limited operation of exclusion of co-operative banks u/s 80P(4) Deductibility of interest received by a Primary Agricultural Credit Society on savings-bank and fixed-deposit investments with a co-operative bank under section 80P(2)(d) - HELD THAT: - Clause (d) allows deduction where a co-operative society derives interest or dividend from investments with another co-operative society; it does... ... ...

Stamp duty valuation of immovable property u/s 56(2)(vii) - Unexplained cash investment in property registration charges Stamp duty valuation of immovable property under section 56(2)(vii) - Addition for the difference between the stamp duty value and agreed consideration of immovable property where the agreement and payment preceded registration - HELD THAT: - Where the agreement fixing the consideration preceded registration and the consideration had been paid through banking channels befor... ... ...

TP Adjustment - Arm's length price determination by prescribed methods - Recharacterisation of independently negotiated commercial agreements - Interest for delayed return filing due to e-filing portal technical glitch - Retrospective statutory amendment and assessment limitation TP adjustment on the sale of identified pharmaceutical business to an unrelated purchaser by reallocating consideration under separate business-transfer and intellectual-property agreements - Arm's length pri... ... ...

Tax deduction at source on reimbursement of deputed employees' salary - Disallowance of unclaimed interest for delayed deposit of TDS Tax deduction at source on reimbursement of deputed employees' salary - Disallowance for non-deduction of tax at source - Liability to deduct tax at source on contributions remitted to the apex cooperative union towards salaries and allowances of supervisory staff deputed to the assessee bank - HELD THAT: - The contributions were remitted to the apex co... ... ...

Validity of Reassessment - mandatory consideration of reply u/s 148A - Unexplained money - recharacterisation after acceptance of explanation Reassessment - non-consideration of reply and supporting bank statements - Defective electronic information - Validity of reassessment initiated on incorrect cash-deposit information when the assessee's timely reply and bank statements u/s 148A were treated as not having been filed - HELD THAT: - Consideration of the assessee's reply and materia... ... ...

TP adjustment for notional interest - Royalty on standardised software - Royalty on international connectivity services - Fees for included services-make available condition - Transfer pricing and treaty source rule for royalties - Advance-tax interest on non-resident income subject to tax deduction at source TP adjustment for notional interest - Interest under Article 11 - requirement of payment - delayed recovery of consideration from associated enterprises - HELD THAT: - The adjustment lac... ... ...

Penalty u/s 271(1)(c) - omission of an amount already assessed and taxed from the return filed u/s 153A - Bona fide and inadvertent error - Concealment and furnishing inaccurate particulars - Inaccurate particulars of income - Penalty not automatic HELD THAT: - The penalty can be imposed only where the assessee has concealed the particulars of her income or has furnished inaccurate particulars of such income. A difference between the income returned and the income assessed does not by itself ... ... ...

Rebate u/s 87A availability against tax computed on short-term capital gains chargeable under section 111A where the assessee opted for the section 115BAC tax regime for Assessment Year 2024-25 HELD THAT: - The issue stood covered in favour of the assessee by coordinate-Bench decisions Pranay M Kothari [2026 (3) TMI 1753 - ITAT CHENNAI] and [2026 (8) TMI 1350 - ITAT JAIPUR] and no contrary decision of the jurisdictional High Court or the Supreme Court was brought to notice. Following the sett... ... ...

Third-party seized loose sheets and on-money receipts from sale of flats - Estimation of profit embedded in unaccounted real-estate business receipts - Telescoping of unaccounted expenditure against on-money receipts - Appealability of initiation of search-related penalty proceedings Third-party seized loose sheets and on-money receipts from sale of flats - Corroboration of seized material - Sustainability and quantification of on-money receipts from sale of flats in the assessee's real-e... ... ...

Reassessment based on external direction - Independent satisfaction of Assessing Officer Validity of reassessment initiated upon a Board instruction where the recorded reasons did not disclose an independent satisfaction of income escaping assessment - HELD THAT: - The interest income forming the basis of the recorded reasons had already been disclosed in the return, albeit treated as invalid, and no material was brought on record to show that the expenses claimed against that income were wro... ... ...

Reassessment beyond four years on change of opinion - Mandatory notice for reassessment after return filed in response to notice Reassessment beyond four years on change of opinion - Failure to disclose material facts - Validity of reassessment initiated after four years in respect of long-term capital gains from sale of equity shares already disclosed and examined in the original assessment - HELD THAT: - Where an assessment has been completed, reassessment beyond four years is permissible o... ... ...

Rectification of typographical error in return of income - Fresh claim in appeal against rectification order - Taxability of real income Whether a typographical error in reporting capital gains in the return of income could be considered in rectification proceedings under section 154 of the Income-tax Act, 1961? - HELD THAT: - In the case of Poorvanchal Vikas Foundation vs. ITO [2022 (8) TMI 263 - ITAT VARANASI] the Tribunal has held that where the assessee, due to some typographical or techn... ... ...

Revisionary jurisdiction - erroneous and prejudicial assessment order - Tax deduction at source on back-to-back reimbursement of debenture interest - Revision on reconciled profit and ICDS adjustments Validity of revision of the assessment for alleged non-deduction of tax on reimbursement of interest paid through a fellow subsidiary to debenture holders - HELD THAT: - Exercise of revisionary jurisdiction requires the assessment order to be both erroneous and prejudicial to the interests of th... ... ...

Interest disallowance on interest-free advances from mixed funds - Cash credit u/s 68 - appropriation of disclosed book profit Interest disallowance on interest-free advances from mixed funds - Presumption regarding availability of interest-free funds - Disallowance of interest expenditure on interest-free advances despite availability of sufficient interest-free partners' capital - HELD THAT: - Where mixed funds are available and the interest-free funds exceed the interest-free advances,... ... ...

Addition for the difference between Form 26AS receipts and returned receipts - Unexplained cash credits - trade creditors for accepted purchases - Rejection of books of account-estimation of net profit Form 26AS reconciliation with service tax receipts - Addition for the difference between receipts reflected in Form 26AS and income offered in the return, where tax was deducted on receipts inclusive of service tax - HELD THAT: - The assessee asserted that the difference arose because two deduc... ... ...

Undisclosed contract receipts - Estimation of profit on unaccounted turnover Attribution of contract receipts reflected in Form 26AS - Unsubstantiated diversion of business receipts - Attribution to the assessee of differential transport-service receipts reflected in its PAN and confirmed by the contractee - HELD THAT: - The contractee's direct confirmation, recording of the transactions in the assessee's name, and the assessee's claim of the entire corresponding TDS credit establ... ... ...