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Cash deposits from proprietary trading activity were supported by business evidence and could not be treated as unexplained money.
Cash deposits in a proprietary trading business bank account were supported by the nature of cash sales and purchases and by evidence of continuing cash availability in preceding and succeeding years. Failure to maintain regular books of account did not by itself justify disregarding the business evidence. The deposits were therefore not treated as unexplained money, and the proposed addition was unsustainable.
Rectification relief under income-tax law made the separate challenge to the original processing intimation infructuous.
Rectification relief granted under section 154 against an intimation issued under section 143(1)(a) rendered unnecessary further adjudication of the appeal challenging the CIT(A)'s remand for reconsideration. Since the assessee had already obtained relief in the appeal concerning the rectification order, the challenge relating to the original intimation became infructuous and was dismissed.
Database and journal subscriptions without copyright or server control are not royalty under domestic law or treaty provisions.
Subscription charges for access to Chemical Abstract Service databases and publication content are not royalty where customers may only search, view, display or print material for personal use. Customers receive no copyright rights or authority to reproduce, amend, exploit or commercially distribute the content, and have no access, control or dominion over the overseas servers. Such receipts constitute consideration for copyrighted articles, not for copyright, industrial, commercial or scientific experience, or equipment. Accordingly, the charges fall outside royalty treatment under Section 9(1)(vi) of the Income-tax Act and Article 12(3) of the India-US DTAA.
Consistent house-property classification protects rental income treatment, while interest and related deduction claims require factual verification.
Rental income from an administrative building remains taxable as income from house property where the property, letting arrangement and activities remain unchanged and prior treatment was consistently accepted; accounting classification or occupant type does not alter its character. Sub-letting charges on materially identical facts are deductible. Interest on borrowed capital used for construction is allowable under the house-property provisions, subject to verification of the borrowing and its use. Expenditure relating to testing, miscellaneous and parking receipts requires factual verification of allowability and nexus. Storage-charge deductions require examination of the receipts' actual nature and whether they were received from members before determining eligibility.
Section 153C satisfaction requirements invalidate search assessments where seized material lacks assessment-year-wise linkage to the other person's income.
Section 153C requires recorded satisfaction that seized material relates to the other person, bears on total income, and is linked to each relevant assessment year. Consolidated satisfaction notes without assessment-year-wise identification of material, or later departmental tabulations seeking to cure omissions, cannot sustain search assessments. Seized thittam books, tally printouts and loose papers require reliable, authenticated nexus to the relevant firm; common partners, inconsistent initials and uncorroborated entries do not establish unexplained income. Protective additions cannot rest on material belonging to separate concerns or unauthenticated loose sheets without independent corroboration. The enhanced Section 115BBE tax rate applies prospectively and not to transactions before 01.04.2017.
Treaty dividend taxation: India-Singapore agreement's beneficial rate governs dividend remittances over the domestic dividend tax rate.
Article 10 of the India-Singapore Double Taxation Avoidance Agreement applies in preference to the domestic dividend tax rate under the Income-tax Act where its beneficial rate governs dividend remittances to a Singapore shareholder. Tax on the relevant dividend is chargeable at the treaty rate of 10%, rather than the domestic rate, favouring the taxpayer.
Employer's failure to deposit deducted tax cannot create employee tax demands or justify adjustment of employee refunds.
Tax deducted by an employer but not deposited cannot be enforced as a demand against the employee. Demands arising from the employer's failure to remit deducted tax were quashed, relieving the employee of the corresponding liabilities. Refunds due for later assessment years could not be adjusted against those unsustainable demands; amounts already set off were required to be refunded. The principle preserves the employee's credit for tax deducted at source and prevents recovery from the employee for the employer's default in depositing it.
Non-recoverable tax demands cannot offset refunds and must be removed from the income-tax portal.
Income-tax demands for the relevant assessment years were not recoverable from the assessee and therefore could not be adjusted against refunds. Recovery was stayed in the system, no further refund adjustments were permissible, and refunds previously adjusted against those demands were to be issued. The demands also had to be removed from the income-tax portal because their continued display was inconsistent with their non-recoverable status.
Definitions - Definition / Legal Terminology
Overseas tour programme package covers a tour package offering a visit outside India and including travel, hotel stay, boarding, lodging, or similar or related expenditure. The definition applies for TDS/TCS purposes under the Income-tax Act, 2025, with a corresponding definition under the Income-tax Act, 1961.
Circular No. Trade Notice No. 1/2025 Dated:- 22-7-2025 Kerala SGST Dated:- 22-7-2025 Kerala SGST
GST registration grievance redressal is facilitated through a dedicated email address for applicants and taxpayers within the Thiruvananthapuram Zone. Grievances must include the application reference number, the relevant Central or State jurisdiction, and a brief description of the issue. Commissioners are to publicise and operationalise the facility among officers and taxpayers, while trade associations and chambers of commerce are requested to disseminate it among their members.
Definitions - Definition / Legal Terminology
Online gaming intermediary means an intermediary offering one or more online games. This definition applies for TDS/TCS purposes under the Income-tax Act, 2025 and is also used in relation to section 194BA of the Income-tax Act, 1961.
FEMA & RBI
Dated:- 20-8-2026
Reservation policy implementation across Public Sector Banks, Public Sector Insurance Companies, sectoral regulators and Public Financial Institutions is being strengthened through a capacity-building workshop. The programme seeks uniform and effective application of Government reservation policies and related welfare measures. Senior human-resource functionaries and Chief Liaison Officers considered practical implementation issues, actionable measures for consistency, and operational concerns. It also focuses on improving accessibility of financial services for Divyangjans.
Circular No. 18/2025 KERALA SGST Dated:- 5-10-2025 Kerala SGST Dated:- 5-10-2025 Kerala SGST
Adverse appellate and judicial orders require immediate scrutiny to assess further appeal and stay options. Proper officers must submit remarks through the Deputy Commissioner to the Joint Commissioner for prompt appellate action, supported by appropriate statements of facts and taken within the applicable limitation or earlier compliance period. Where no further remedy is available, appellate or judicial directions must be complied with promptly after confirming exhaustion of legal recourse. Taxpayers or concerned parties must be informed of appeal and stay status whenever compliance is withheld.
Definitions - Definition / Legal Terminology
Licensor or lessor for TDS/TCS purposes means a person transferring, by lease, licence, contract or otherwise, a whole or partial right or interest in a parking lot, toll plaza, mine or quarry to another person for business use. A public sector company is excluded. No corresponding definition exists under the Income-Tax Act, 1961.
Search-assessment additions require incriminating material; derivative trading is taxed on proven profit, not peak ledger credits.
Search-assessment additions require a nexus with incriminating material and cannot rest on unsupported estimates or uncorroborated declarations. Foreign derivative activity was taxable only to the extent of established trading profit, not on peak-credit basis; the initial-investment addition was deleted. Reversed, reconciled or temporary bullion-ledger entries, invoiced premium payments, hedging losses, interest expenditure, and unsupported property and cheque-purchase allegations did not justify additions. Credits lacking adequate substantiation, estimated deemed rent for a second residence, and commission disallowed for failure to deduct tax remained taxable or disallowable. The account was treated as beneficially owned by the assessee, but its derivative-trading character governed the taxable income computation.
Unverified purchase verification is restored, unexplained jewellery addition survives, and bank-certified housing-loan interest deduction is allowed.
Unverified purchases from three suppliers require fresh verification where books and stock records were not rejected, sales were accepted, and purchase additions were based on estimated suppressed profit; the matter is restored for decision on merits. Jewellery found during search remains taxable as unexplained to the extent not covered by the reasonable allowance under CBDT Instruction No. 1916, because the claim of ownership by a separately residing married daughter lacked supporting search statements and valuation records. Housing-loan interest supported by a bank certificate is allowable, as the additional evidence was undisputed; the related disallowance is deleted.
News and Press Release
Dated:- 20-8-2026
DPIIT's collaborations with PhonePe and Shell India create support mechanisms for DPIIT-recognised startups through technology access, digital infrastructure, mentorship, market opportunities and industry networks. PhonePe will provide transaction credits, access to the Indus AppStore, onboarding support, brand visibility, and training on fintech, sales, go-to-market strategy and business scaling. Shell India will assist energy and climate-tech startups through mentorship, strategic guidance, investor and incubator connections, participation opportunities, and knowledge-sharing materials on innovation and best practices.
News and Press Release
Dated:- 20-8-2026
India-Singapore economic cooperation was advanced through ministerial, business and government-to-business engagements focused on deepening bilateral trade, investment, technology and commercial linkages. Discussions addressed agri-exports, GCC-based commercial parks, fintech and sustainable infrastructure, alongside expanding agricultural market linkages. The engagements reinforced commitment to strengthening trade, investment, technology and business-to-business cooperation.
Notification No. LG-1-7/2020/4376 & 4377/LEG 1 Dated:- 10-8-2020 Bihar SGST
Bihar Goods and Services Tax law is amended to empower the Government, on the Council's recommendations, to extend statutory time limits by notification where compliance or completion of actions is prevented by force majeure. Notifications may have retrospective effect, subject to the stated commencement limitation. Force majeure includes war, epidemic, flood, drought, fire, cyclone, earthquake and other calamities affecting implementation of the law. Actions taken under the repealed amendment ordinance are preserved and treated as taken under the amended law.
Definitions - Definition / Legal Terminology
Licensee or lessee for TDS and TCS purposes means a person, excluding a public sector company, who obtains a lease, licence, contract, right, or interest, wholly or partly, in a parking lot, toll plaza, mine, or quarry from a licensor or lessor for business use. No corresponding definition exists under the Income-tax Act, 1961.