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2025 (3) TMI 2230
Case Laws Income Tax
Co-operative society investment interest from a District Co-operative Bank qualifies for deduction under the specific co-operative investment provision.
Interest earned by a co-operative society from investments with a District Co-operative Bank registered as a co-operative society under Kerala co-operative law falls within the deduction for interest or dividend derived from investments with another co-operative society. The interest is not deductible under the business-income clause, but qualifies under the specific deduction provision for investments with co-operative societies. Accordingly, the interest is deductible under Section 80P(2)(d) of the Income-tax Act, 1961.

2025 (3) TMI 2231
Case Laws Income Tax
Property management power of attorney does not shift settled rental income back to the settlor for tax assessment.
Rental income from property settled in favour of family transferees is not assessable in the settlor's hands merely because the settlor holds a power of attorney for property management. The transferees held ownership and offered the rental income to tax, while no clubbing provision applied. A management-focused power of attorney does not transfer title or alter ownership. Consequently, rental income from the settled portions falls outside the settlor's assessment under income from house property, and the related addition is deleted.

2025 (3) TMI 2232
Case Laws Income Tax
Cottage industry deduction denied where a co-operative printing press failed to establish satisfaction of applicable eligibility criteria.
Deduction available to a cottage industry was denied to a co-operative society operating a printing press because no material established that it satisfied the applicable cottage-industry criteria. The determination denying the claimed deduction therefore remained undisturbed, and the society was not entitled to the deduction.

2025 (3) TMI 2233
Case Laws Income Tax
Section 80P deduction requires a valid income-tax return; failure to file one defeats the statutory claim.
Deduction under Section 80P requires a claim in a valid return of income under Section 80A(5). Filing a valid return is a mandatory statutory precondition for Chapter VI-A relief, and deductions or exemptions under taxing statutes are strictly construed. Where no return is filed under Section 139 or in response to a notice under Section 142(1), the statutory condition remains unmet and deduction under Section 80P is unavailable.

2025 (3) TMI 2234
Case Laws Income Tax
Section 80P deduction requires a valid statutory return; an unclaimed deduction cannot be entertained after filing non-compliance.
Deduction under Section 80P requires a primary agricultural credit co-operative society to make the claim in a return of income recognised under the Income-tax Act, 1961. Section 80A(5) makes filing a valid return within the applicable statutory period, including a return filed under Section 139 or in response to a notice under Section 142(1), a precondition for claiming a Chapter VI-A deduction. Where no such valid return is filed, the deduction cannot be entertained. Tax deductions and exemptions are subject to strict construction, and failure to meet this return-filing requirement cannot be condoned.

2025 (3) TMI 2235
Case Laws Income Tax
Termination-related ex-gratia compensation constitutes profits in lieu of salary and is taxable as salary income.
Ex-gratia compensation received from a former employer in connection with termination of employment falls within profits in lieu of salary under Section 17(3) of the Income-tax Act, 1961. Such termination-related compensation is taxable as salary income. A precedent predating insertion of the relevant statutory provision does not govern the tax treatment of the payment.

2025 (3) TMI 2236
Case Laws Income Tax
Co-operative society interest income qualifies for deduction when surplus deposits remain connected with regulated credit-facility business.
Interest received by a primary agricultural credit co-operative society from deposits of surplus profits with a District Co-operative Bank and the Treasury qualifies for deduction under Section 80P(2)(d). Depositing surplus funds with a permitted bank or financial institution, where regulated or permitted by co-operative-societies law, does not alter the income's connection with the society's credit-facility business. Prudent deployment of surplus profits instead preserves and enhances profits arising from that principal business, supporting the deduction for the interest income.

2025 (3) TMI 2237
Case Laws Income Tax
Delayed Form 10B filing cannot justify rectification where exemption was granted and no departmental prejudice arose.
Delayed digital filing of Form 10B was treated as directory rather than mandatory where the form was available to the CPC during processing under Section 143(1), the returned income was accepted, and exemption under Section 11 was granted. No prejudice to the Department arose from the delay. Suo motu rectification under Section 154 to withdraw the exemption, without an opportunity of hearing, was considered contrary to natural justice and beyond the limited scope of rectification. The rectification denying exemption was invalid, and the original intimation granting exemption was restored.

2025 (3) TMI 2238
Case Laws Income Tax
Freight expenditure disallowance restricted where the record did not justify a higher ad hoc disallowance.
Freight expenditure incurred for transporting goods purchased at Mumbai from Delhi-based dealers importing and selling goods at Mumbai Port was subject to an ad hoc disallowance. The available record did not support sustaining a higher disallowance. Given the stated factual circumstances, the disallowance was restricted to 5% of the claimed freight expenditure, and the balance disallowance was deleted in favour of the assessee.

2025 (3) TMI 2239
Case Laws Income Tax
Reassessment jurisdiction fails when Explanation 2(1) is invoked despite the assessee having filed the relevant income-tax return.
Explanation 2(1) to Section 147 applies only where an assessee has not furnished a return despite having taxable income above the maximum amount not chargeable to tax. Where the assessment record shows that a return was filed for the relevant assessment year, invoking that Explanation is inapplicable. Reliance on an inapplicable provision renders the recorded reasons for reopening and the consequential reassessment jurisdictionally defective, resulting in the reassessment being void ab initio and liable to be quashed.

2025 (3) TMI 2240
Case Laws Income Tax
Section 14A disallowance fails without exempt income, and revision cannot replace an Assessing Officer's examined view.
Revision under section 263 cannot rest on a different view where the Assessing Officer conducted enquiries, issued statutory notices, obtained replies and examined relevant material; inadequate enquiry differs from complete absence of enquiry. For the relevant assessment years, the Finance Act 2022 Explanation to section 14A applied prospectively, and section 14A read with Rule 8D did not permit disallowance where no exempt income was earned. Consequently, assessment orders allowing no such disallowance were neither erroneous nor prejudicial to Revenue interests, rendering the revisionary orders invalid and liable to be quashed.

2025 (6) TMI 2155
Case Laws Income Tax
Cash loan verification under revision powers permits assessment enquiry where banking-channel evidence is absent and section 269SS exposure arises.
Revision under section 263 was valid where assessment records showed receipt of an unsecured cash loan and the assessee's assertion that no cash transaction occurred lacked documentary support. Verification was required to determine whether the loan had been received through banking channels and whether penalty proceedings for a possible violation of section 269SS were warranted. The revisionary direction appropriately required the Assessing Officer to conduct the enquiry while allowing the assessee an opportunity to substantiate the claim.

2025 (8) TMI 1849
Case Laws Income Tax
Capital gains on SARFAESI property sales apply to full consideration despite bank appropriation of proceeds toward secured debt.
Capital gains arise when a bank sells an assessee's mortgaged immovable property under the SARFAESI Act, even if the sale proceeds are applied to discharge secured loan dues. Where the assessee owns the property, capital gains are computed on the full sale consideration realised on sale, rather than only any amount retained or received by the assessee. Appropriation of proceeds towards credit facilities secured by the mortgage does not negate the transfer or reduce the consideration for capital-gains computation, subject to admissible deductions.

2025 (7) TMI 2062
Case Laws GST
Cross-examination rights in suppressed turnover disputes require fresh adjudication where material transactions are contested as advances.
Denial of an opportunity to examine or cross-examine a person whose transactions formed the basis for treating amounts as suppressed turnover prejudices the taxpayer where the transaction's nature is materially disputed. The taxpayer sought to establish that the amounts were advances rather than turnover, and the taxpayer's documents and books-of-account data also required consideration. Fresh adjudication is required after permitting examination of the material person and considering the relevant records.

GST
Dated:- 11-8-2026
PTI
Alleged bribery in GST inquiry closure led to the arrest of a Sales Tax Assistant Commissioner after a scrap trader complained of a demand for illegal gratification to close an inquiry initiated through a GST show-cause notice. Anti-corruption officials reportedly verified the allegation through intermediaries, during which the officer allegedly agreed to accept payment for closing the matter. A criminal case was registered under the Prevention of Corruption Act, with further investigation ongoing.

Income Tax
Dated:- 11-8-2026
PTI
Net direct tax collections increased by 23 per cent to over Rs 8.11 lakh crore through August 10, driven by higher non-corporate tax collections and slower refund growth. Gross direct tax collections grew by 19.75 per cent to about Rs 9.55 lakh crore. Net corporate tax collections rose about 20 per cent, net non-corporate tax collections rose 23 per cent, and Securities Transaction Tax collections increased 51 per cent. Refund issuances grew by 3.8 per cent year-on-year.

Corp. Laws / SEBI / IBC
Dated:- 11-8-2026
PTI
Vicarious criminal liability for cheque dishonour under section 141 of the Negotiable Instruments Act does not extend to a trust, because a trust is not a juristic person. A person cannot be summoned merely for alleged active involvement in a trust where the person was neither drawer nor signatory of the cheques, trustee, office-bearer, authorised account operator, guarantor, or executor of transaction documents.

FEMA / RBI
Dated:- 11-8-2026
PTI
Cross-border payment integration is under discussion through potential linkages between central bank digital currencies and fast payment systems, including UPI-type platforms. These approaches seek faster and less costly trade and remittance transfers, particularly retail payments, but remain at a discussion stage. Rupee internationalisation is also being pursued through central-bank memorandums of understanding for bilateral trade settlement in local currencies, with existing arrangements covering Indonesia, Maldives, Mauritius and the UAE.

News and Press Release
Dated:- 11-8-2026
PM GatiShakti National Master Plan provides an integrated, data-driven infrastructure planning framework using geospatial data, satellite imagery and API integration. Project approval, implementation and funding remain with the respective Central Ministries, Departments and States or Union Territories under their own plans and budgetary provisions; the framework sets no separate budgetary allocation or quantified targets. The Network Planning Group evaluates critical Central Government projects at the planning stage for multimodality, synchronisation, last-mile connectivity, comprehensive local development and coordinated decision-making.

News and Press Release
Dated:- 11-8-2026
GeM uses AI/ML analytics to detect order splitting, suspicious bidding, abnormal pricing, repeated participation and potential buyer-seller collusion. Flagged cases are placed before buyer organisations for review and action, while suspected cartels are assessed through digital-footprint, pricing and bid-timing indicators. Its Incident Management framework addresses false documents, fraud, collusive behaviour and other misconduct through administrative measures, including suspension. Anti-competitive conduct and cartel formation are Severe/Grave deviations, with proven cases attracting suspension for up to 365 days.

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